ML20046C546

Requests Review & Approval of Proposed Changes to QA Program as Described in Unit 1 Usar.Lists Structure Currently in Place W/Exception of Changes Identified by Toed as Reducing Commitments Currently Contained in Usar,Chapter 17.2

ML20046C546
Person / Time
Site:	Davis Besse
Issue date:	08/05/1993
From:	Storz L CENTERIOR ENERGY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
2167, NUDOCS 9308110124
Download: ML20046C546 (32)

Text

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CENTERIOR ENERGY Louis F. Sforz 300 Madison Avenue Vice President - Nuclear Toledo, OH 43652-0001 Dwis-Besse (419)249-2300 Docket Number 50-346 License Number NPF-3 Serial Number 2167 August 5, 1993 United States Nuclear Regulatory Commission Document Control Desk Vashington, D. C.

20555 Subj ec t :

Request for NRC Approval Pursuant to 10 CFR 50.54(a)(3)

Gentlemen:

This letter is to request review and approval of proposed changes to the Davis-Besse Nuclear Power Station (DBNPS) Quality Assurance Program as described in the DBNPS Unit 1 Updated Safety Analysis Report (USAR).

This letter supersedes Toledo Edison's previous submittal dated July 9, 1993 (Serial 2157) in its entirety.

As part of Toledo Edison's ef forts to improve quality and vork process efficiency and to achieve organizational consolidation and realignment, Davis-Besse recently implemented a reorganization.

The reorganization consisted of modifying the existing five director functional arrangement to four directors vith the associated realignment of activities to accommodate this new structure. Reporting to the Vice President - Nuclear vill be:

1) the Plant Manager, responsible for operations, maintenance, radiation protection and security; 2) the Director - Engineering, responsible for design engineering, plant engineering, and nuclear engineering; 3) the Director - Nuclear Services, responsible for material management, planning, regulatory affairs and training; and 4) the Director - Nuclear Assurance, responsible for quality control, quality assessment, and quality services. Activities currently being performed at the DBNPS vill be maintained in the new organization.

The above structure is currently in place with the exception of the changes which have been identified by Toledo Edison as reducing commitments currently contained within the Updated Safety Analysis Report (USAR) Chapter 17.2, Quality Assurance Program for Station Operation. The first reduction in Quality Assurance Program c:eveiono Deanc muminating

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-Docket Number 50-346 License Number NPF-3 Serial Number 2167

~Page 2 commitments proposes that the Director - Nuclear Assurance vill be responsible for non-quality assurance related. functions of the--Quality j

Services Section and adds operational experience assessment activities j

to the functions performed by the Quality Control Section.

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The second reduction in commitment involves having Independent Safety Engineering report to the Director - Nuclear Assurance rather than-directly to the Vice President - Nuclear. The Manager - Quality j

Control, who will report to the Director - Nuclear Assurance vill have responsibility for managing Independent Safety Engineering.

Toledo Edison has evaluated these proposed program reductions as described in the attachment to this letter and concludes that, with, i

their implementation, the Quality Assurance Program vill continue to satisfy the criteria of 10 CFR Part 50, Appendix B.

It is Toledo Edison's desire to expeditiously implement these f

organization changes. Accordingly, Toledo Edison requests prompt NRC review of these proposed Quality Assurance Program reductions.

Should you have any questions or require additional information, please l

contact Mr. Dale R. Vuokko, Manager - Nuclear Licensing (Acting), at (419) 249-2366.

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Very truly yours,

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l Docket Number 50-346' License Number NPF-3 JSerial Number 2167 i

i Listing of Submittal Contents Davis-Besse Unit 1 USAR Section 17.2, Quality Assurance.

i Program for Station Operation, Pages Affected by Proposed i

Changes

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Attachment.2 Evaluation of Proposed Quality Assurance Program Reductions'

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Docket Number 50-346

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'Page 1 Note The attached marked up USAR Section 17.2 includes several changes made prior to the proposed change of Quality Assurance to Nuclear Assurance.

The elimination of the Manager - Quality Systems occurred in October 1992 (reference:

USAR Change Notice (UCN)92-081). The responsibilities of the Manager - Quality Systems were divided among the remaining Quality Assurance Sections (Quality Verification and Quality Control). This change did not reduce commitments identified in the. Quality Assurance Program. Another change that was made eliminated the day-to-day, in-line quality reviev of specification and modification packages performed by the Engineering Assurance Unit (reference:

UCN 92-058). This change was approved by the NRC on October 30, 1992 (Toledo Edison Log 1-2721). The remaining Engineer.ing Assurance functions (i.e., assessment of engineering' activities and products and plant chemistry issues) have been assimilated into the Quality Assessment Section (reference UCN 93-044). This change did not reduce commitments identified in the Quality Assurance Program.

-Docket !Jumber 50-346 License Number NPP-3 Serial Number 2167 Page 2 i

I ose non ga1\\d 453Utnnte felnl+d f

eg 17.2.1.4 Toledo Edison Nu,1Eear Group 9#

(JUCLEAFs 14 DIRECTOR - QUAbtTY ASSURANCE Ac.

l1 TheDirector--Quehc Assurance reports to the Vice President - Nuclear and is responsible for the development, maintenance, and monitoring of the Nuclear 14 Quality Assurance Program. The Director is also responsible for advising the Plant Manager and cognizant corporate managfmyt, of the Quality Assurance Program's effectiveness. The Director - 4 #Mty Assurance is independent l14 from cost and scheduling considerations when opposed to safety considerations, 1

and is free of non-QA related dutiesf. He is authorized to identify quality problems initiate, recomend, or provide solutions, through l9 designated channelst verify implementation of solutions: and verify l1 cof rmance to established quality requirements. The Director -

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M "~ $ Assurance has the authority to suspend (stop work) any activity, l14 except reactor operation, not in conformance with specified requirements 1

and/or provisions of the NQAM. Conditions adverse to quality that appear to warrant suspension of reactor operation, including startup or power g

at,lon are imediately reported to the Plant Manager. The Director g

+7 Assurance is responsible for the adequate staffing of the 14 ty Assurance Department to ensure that the requirements of the HQAM are effectively implemented.

1 4

MANAGER - QUALITY CONTROL 9

The Manager - Quality Control reports to the Director - Quality Assurance and l14 is responsible for managing the Quality Control staff in the quality review, l1 inspection, and examination of plant structures, systems, and components 14 within the scope of the Nuclear Quality Assurance Program to assure compliance to procedural, drawing, and engineering specification requirements. This responsibility includes the inspection of welding to verify it meets ASME, National Board, and State of Ohio requirements in 1

addition to coordinating the activities of the Authorized Inspection Agency to ensure Code compliance.

I nserl O 17.2-4 REV 16 7/92

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~ Docket Number 50-346 Li. cense Number NPF.

Serial Number 2167 -

Page 3 i

Insert A The Director - Nuclear Assurance is also responsible for directing the activities of independent safety engineering, engineering assurance and the review of external information and plan + operations assessments.

The Director - Nuclear Assurance is responsible for managing support services associated with procedure control, records management and j

document control.

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Insert B 6

The Manager - Quality Control is also responsible for development and maintenance of the ASME Quality Assurance Manual and Quality Control.

l and selected Nuclear Assurance Department Procedures. The Manager -

Quality Control is also responsible for review of_all corrective action documents for close-out, review of selected site procedures, receipt inspections, vendor surveillances and review of vendor supplied j

documentation, and Quality control Staff training. The Manager -

Quality Control is also responsible for providing technical expertise onsite to allow for systematic and independent assessment of plant activities by the independent safety engineering function.

Additional responsibilities include' surveillance of plant operations and maintenance activities to provide independent technical verification that these activities are performed correctly, and investigation of plant-incidents which may affect the underlying assumptions,in the USAR Accident Analysis.

The Manager - Quality Control is also responsible for the review of all external information received in support of improved performance and reliability and for plant operations assessments.

. Docket flumber 50-346 i

",Licen;;e 11 umber 11PF-3 D-B Serial fJumber 2167

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Page 4 9

r ASSESSMC:M r 8

c MANAGER - 00ALITY "EnITICATICIT 9

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Hvelmr The Manager - Quality derificction reports directly to the Director --Quelity l14 1

Assurance and is responsible for managing the Quality verification staf f in the performance of internal and celee!~1 external OA audits, and for OA 8

surveillance of station operations.

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-etivi les v thin t Quali System anager s area f resp nsibil y ine de the ovelo ent a revisi of th 14ucles and AS Qual y Assu nee H nuals an Quali y Assu nee De rtment rocedur s, Int -depar ent Pr cedur Revie,

9 C rect e Act n Docum t Clos e, Qua ty Ass ance partme. Trai ng, uali Trend g and alysis, endor udits/S rveill.ces, R view a d Appr val of V dor 0 lity As urance P ograms rocedu s, maiptainin the A roved Ve or Lis, Recei Inspec on, a Vendor upplip Docum tatio Revie,

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Docket Number 50-346 i

Li. cense Number NFF-3 Serial Number 2167

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Page 5 i

Insert C The Manager - Quality Assessment is also responsible for development and maintenance of Quality Assessment and selected Nuclear Assurance Department Procedures, review of inter-department procedures, selected site procedures, the review and approval of Vendor Quality Assurance Programs and Procedures, performance of vendor audits, review of

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selected procurement documents, and control of the approved vendors list. The Manager - Quality Assessment is also responsible for the development, maintenance and implementation of the trending and analysis program and Quality Assessment staff training. The Manager -

Quality Assessment is also responsible for the independent assessment l

of engineering activities and products, and review and evaluation of plant chemistry and radiochemistry issues.

I Insert D Manager - Quality Services j

The Manager - Quality Services reports to the Director - Nuclear

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Assurance and is responsible for the development and maintenance of the Nuclear Quality Assurance Manual, managing support services associated with quality and non-quality records, document control, inter-department procedure related activities and administrative services.

Docket Number 50-346 License Number NPF-3 o

Serial Number 2167 Page 6 D-D HANAGER ~ hEPENDDTT f dLTY EfJGJ[EERING' l9 l

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1 The K ager - Inde 4ndent Sa tty Engin ring rep ts direct to the ce 9

Pre dent - Nuc ar, and i responsi e for pr 'iding te ilcal exp tisc 9

-site to al v for sys ematic an independ t assessm t of pla 6

activities. Addition responsi J.ities i ude surv 11ance o plant 5

operatio and main >>ance act' ities to rovide in > pendent chni-S

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incident" *hich ma* affect th underlyi assumpt' ns in 5

th USAR Acci nt Analys'. The I Departme functior inde ently from 8

. her Nuclegt Group ac vities.[

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C0KPANY NUCLEAR REVIEV BOARD i

The Company Nuclear Reviev Board (04RB) is responsible for providing an independent review and audit of activities affecting quality to assure itself that Davis-Besse is being operated and maintained in compliance with the Nuclear Quality Assurance Program and the Operating License. The nature of Q1RB activities include the monitoring and review of functions 5

and problems pertaining to nuclear safety. The Chairman of the C1RB is responsible for providing a CNRB Charter which meets the requirements of Section 6 of the Technical Specifications.

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STATION PEVIEU BOARD 1he Station Reviev Board (SRB) is responsible for the review of Plant Admin-1 istrative procedures, data, and deficiencies related to nuclear safety as 1

identified in the SRB Charter. The SRB may, as it determines necessary 7

direct investigations by Station personnel of facility activities to assure 1

that these activities have been, are being, and vill be performed in 1

accordance vith approved vritten procedures. Generally, the SPS is 1

concerned with the nuclear safety related aspects of facility operation and 7

coordinates its activities with Quality Assurance to satisfy the OA 1

requirements for facility operation. The Chairman of the SRB is responsi-1 ble for providing an SRB Charter which meets the requirements of Section 6 1

of the Technical Specifications.

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Docket Number 50-346 I

License Number NPF-3 Serial Number 2167

'Page 1 t

10CFR50.54 EVALUATION FOR UCN 93-032, REVISION 01 (EVALUATION OF PROPOSED QUALITY ASSURANCE PROGRAM REDUCTIONS)

PROPOSED CHANGES

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The proposed changes to the Updated Safety Analysis Report (USAR)

Chapter 17.2, Quality Assurance Program for Station Operation, are shown on the attached marked up pages of Section 17.2.1.4, including Figure 17.2-1, (Toledo Edi.9on Nuclear Group) and are revisions to previous UCNs93-028, 93-032 and 93-044.

l Description of Change 1 (Pages 17.2-4, 17.2-5 and 17.2-11a and b)

A) Modify the phrase "and is free of non-0A related duties..." by adding the clarification of: "...except for those non-0A related functions of the Manager - Quality Services."

B) Transfer the responsibilities for "the review of all external information received in support of improved performance and reliability and for plant operations assessments" to the Director - Nuclear Assurance (through the Manager-Quality Control) from the Manager - Regulatory Affairs.

C) Change the title of Manager - Plart Services to Manager -

Quality Services and shift reporting of the Manager - Quality (Plant) Services to the Director - Nuclear Assurance from the l'

Director - Nuclear Services. Transfer the non-0A functions of

" site-vide procedure control, records management, document control, and administrative services" to the position of Director - Nuclear Assurance (through the Manager - Quality Services).

Description of Change Number 2 (Pages 17.2-4 and 17.2-11c)

Shift the responsibilities for " independent safety engineering" to the position of Director - Nuclear Assurance (through the Manager - Quality Control) from the deleted position of the Manager - Independent Safety Engineering presently reporting directly to the Vice President Nuclear and presently functioning independently from other. Nuclear Group departments. These responsibilities include "providing technical expertise onsite to allow for systematic and independent assessment of' plant activities" and " surveillance of plant operations and maintenance activities to provide independent technical verification that these activities are performed correctly, and investigation of plant incidents which may affect the underlying assumptions in the USAR

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Accident Analysis".

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Docket Number 50-346 LJcense Number NPF-3 Serial Number 2167-i Page 2 Reason for Changes To support the Centerior Energy reorganization.

To allow the Director - Nuclear Assurance to assume other responsibilities for performing additional quality assurance and some non-quality assurance functions as described above.

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Effect of Change 1 A) ELIMINATION OF "NON-0A DUTIES" RESTRICTION ON QA DIRECTOR Under the proposed Davis-Besse Nuclear Power Station reorganization, the position of Director - Nuclear Assurance (presently the position of Director - Quality Assurance) vill no longer be " free of non-0A l

related duties" as stated in USAR Section 17.2.1.4 of the Quality

l Assurance Program for Station Operation.

The phrase "and is free of non-0A related duties" is not a requirement of 10CFR50 Appendix B, Quality Assurance Criteria for l

Nuclear Power Plants, Criterion I - Organization. The requirements' of Criterion I do not preclude persons and organizations performing l

quality assurance functions from performing non-quality assurance l

functions when such

f. unctions do not affect the safety related functions of structures, systems, and components.

The basis for concluding that the new position of Director - Nuclear Assurance, with the modification of non-0A reltted duty restrictions, vill continue to satisfy the requirements of 10CFR50 j!

Appendix B follows:

Under provisions of-10CFR50 Appendix B, Criterion I, persons and organizations performing quality assurance functions must have i

sufficient authority and organizational freedom to identify quality j

problems; to initiate, recommend, or provide solui ns; and to

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verify implementation of solutions. It also requi,es those persons and organizations performing quality assurance functions to report to a management level such that the required authority and organizational freedom, including sufficient independence from cost and schedule when opposed to-safety considerations, are provided.

The proposed changes and USAR 17.2.0, Policy, establish sufficient authority and organization freedom, and sufficient independence from cost and schedule when opposed to safety considerations for.the quality assurance function and continue to satisfy the provisions of 10CFR50 Appendix B, Criterion I.

B) TRANSFER OF "0PERATIONS EXPERIENCE ASSESSMENT (OEAP)" ACTIVITIES TO NUCLEAR ASSURANCE The Director - Nuclear Assurance assumes the responsibilities for "the review of all external information received in support of j

improved performance and reliability and for plant operations assessments" (through the Manager - Quality Control) from the

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Docket Number 50-346 License Number NPP-3

.S'erial Number 2167 Page 3 l

Hanager - Regulatory Affairs.

The transfer of these OEAP activities with ISEG activities (See Effect of Change 2) to Nuclear Assurance (Quality Control) consolidates responsibility for similar overviev activities.

i The basis for concluding that this organizational change regarding the new position of Director - Nuclear Assurance continues to satisfy the requirements of 10CFR50 Appendix B follows:-

This additional responsibility provides activities which are f

considered to be an enhancement of quality assurance functions described in 10CFR50 Appendix B, Criterion I.

The audit and surveillance activities of the Manager - Quality Assessment will remain independent of these functions just as they have in evaluating existing Quality Control functions.

C) TRANSFER OF " PLANT SERVICES" ACTIVITIES TO NUCLEAR ASSURANCE The Director - Nuclear Assurance (through the Hanager - Quality Services) assumes the non-0A functions of site-vide procedure control, records management, document control, and administrative services from the deleted positions of Director - Planning and Support and Manager - Engineering Assurance and Services.

The basis for concluding that this organizational change regarding

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the new position of Director - Nuclear Assurance continues to i

satisfy the requirements of 10CFR50 Appendix B follows:

I These additional responsibilities are considered to be non-quality assurance functions which do not affect the safety related functions

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of structures, systems and components. The audit and surveillance' j

activities of the Manager - Quality Assessment will remain j

independent of these functions just as they have in evaluating j

existing Quality Control functions.

Effect of Change Number 2 i

TRANSFER OF " INDEPENDENT SAFETY ENGINEERING (ISEG)" ACTIVITIES TO NUCLEAR ASSURANCE The Director - Nuclear Assurance (through the Manager l-Quality Control) assumes the responsibilities for " independent safety engineering" from the deleted position of the Manager - Independent y

Safety Engineering presently reporting directly to the Vice l

President - Nuclear.and presently functioning independently from' other Nuclear Group departments. The transfer of these ISEG activities with OEAP activities (See Effect of Change IB) to Nuclear Assurance (Quality control) consolidates responsibility for similar overview activities.

The function of independent safety engineering is neither a Technical Specification nor a 10CFR50 Appendix B requirement for Davis-Besse.

Docket Number 50-346 I

License Number NPF-3 Serial Number 2167 Page 4 l

Under the proposed change, the Manager - Quality control, who will j

report to the Director - Nuclear Assurance, vill have responsibility for the function of independent safety engineering.

The independent safety engineering function vill no longer be a separate area which reports directly to the Vice President - Nuclear, as previously described. The level of independence for independent safety engineering activities is established in USAR Section 17.2.0, Policy. To adequately fulfill assigned responsibilities of the Director - Nuclear Assurance, the policy allows the Director -

Nuclear Assurance access to the Chairman (President and Chief Executive Officer) if the need for such access exists. The organizational freedom described is considered to be sufficient for independent safety engineering activities.

The basis for concluding that this organizational change regarding the new position of Director - Nuclear Assurance continues to satisfy the requirements of 10CFR50 Appendix B follows:

These additional responsibilities provide activities which are considered to be an enhancement of the quality assurance functions described in 10CFR50 Appendix B, Criteria'I, and are appropriately organizationally structured for that purpose. The audit and surveillance activities of the Manager - Quality Assessment vill remain independent of these functions just as they have been in evaluating existing Quality Control functions.

l BASIS FOR CONCLUSION THAT CHANGES CONTINUE TO SATISFY THE CRITERIA 0F 10CFR50 APPENDIX B In summary, the Director - Nuclear Assurance vill have the following functional responsibilities in addition to the quality-assurance responsibilities presently held: independent safety engineering, the review of external information, plant operations assessments, site-vide procedure control, records management, document control,.

and administrative services.

The basis for concluding that the organization changes, identified above, continue to satisfy the requirements of 10CFR50 APPENDIX B, is as follows:

1) The proposed changes vill not diminish or reduce the effectiveness of the quality assurance functions as currently described.

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Docket Number'50-346 License Number NPF-3 l

Serial Number 2167 i

Page 5 l

2) The changes continue to provide sufficient authority and

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organizational freedom of the quality assurance functions to identify quality problems and sufficient independence from cost l

and schedule vhen opposed to safety considerations.

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3)'The changes provide an independent organization to function in a strong overview capacity, utilizing both compliance and performance based approaches.

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4) The changes provide an overview function with a high level of expertise and management involvement in areas such as:

traditional quality assurance activities and overviews and l

assessments of engineering activities, operational activities, and industry experience.

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5) The audit and surveillance activities of the Manager - Quality l

Assessment vill remain independent of all these additional f

functions just as they have in evaluating existing Quality Control functions.

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6) The Quality (Nuclear) Assurance department is periodically assessed by the Company Nuclear Review Board (CNRB)~and by external organizations such as NRC, INPO, and the Joint Utility Management Assessment (JUMA) team.

Similar assessments of these additional Nuclear Assurance functions vill be periodically l

performed.

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This reorganization is perceived to enhance Toledo Edison's goals i

in providing safe and reliable operation of the Davis-Besse

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Nuclear Power Station.

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CENTE.R.00R_

E Louis F. Storz 300 Modison Avenue Vice President - Nuclear Toledo, OH 43652-0001 Davis-Besse (419)249-2300 Docket Number 50-346 License Number NPF-3 Serial Number 2167 August 5, 1993 United States Nuclear Regulatory Commission Document Control Desk Vashington, D. C.

20555

Subject:

Request for NRC Approval Pursuant to 10 CFR 50.!4(a)(3)

Gentlemen:

This letter is to request review and approval of proposed changes to the Davis-Besse Nuclear Power Station (DBNPS) Quality Assurance Program as described in the DBNPS Unit 1 Updated Safety Analysis Report (USAR).

This letter supersedes Toledo Edison's previous submittal dated July 9, 1993 (Serial 2157) in its entirety.

As part of Toledo Edison's efforts to improve quality and work process efficiency and to achieve organizational consolidation and realignment, Davis-Besse recently implemented a reorganization. The reorganization-consisted of modifying the existing five director functional arrangement to four directors with the associated realignment of activities to accommodate this new structure. Reporting to the Vice President - Nuclear vill be:

1) the Plant Manager, responsible for operations, maintenance, radiation protection and security; 2)_the Director - Engineering, responsible for design engineering, plant engineering, and nuclear engineering; 3) the Director - Nuclear Services, responsible for material management, planning, regulatory-affairs and training; and 4) the Director - Nuclear Assurance, responsible for quality control, quality assessment, and quality services. Activities currently being performed at the DBNPS vill be maintained in the new organization.

The above structure is currently in place with the exception of the changes which have been identified by Toledo Edison as reducing commitments currently contained within the Updated Safety Analysis Report (USAR) Chapter 17.2, Quality Assurance Program for Station Operation. The first reduction in Quality Assurance Program Operahng Componies:

Clevelond Doctnc muminating Toledo Edison

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Docket Number 50-346 l

License Number NPF-3 Serial Number 2167 j

Page 2 commitments proposes that the Director - Nuclear Assurance vill be

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responsible for non-quality assurance related functions of the Quality I

Services Section and adds operational experience assessment activities

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to the functions performed by the Quality Control Section.

The second reduction in commitment involves having Independent Safety Engineering report to the Director - Nuclear Assurance rather than directly to the Vice President - Nuclear. The Manager - Quality Control, who vill report to the Director - Nuclear Assurance vill have responsibility for managing Independent Safety Engineering.

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Toledo Edison has evaluated these proposed program reductions as l

described in the attachment to this letter and concludes that, with i

their implementation, the Quality Assurance Program vill continue to satisfy the criteria of 10 CFR Part 50, Appendix B.

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It is Toledo Edison's desire to expeditiously implement these organization changes.

Accordingly, Toledo Edison requests prompt NRC review of these proposed Quality Assurance Program reductions.

Should you have any questions or require additional information, please contact Mr. Dale R. Vuokko, Manager - Nuclear Licensing (Acting), at p

(419) 249-2366.

Very truly yours, l

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JMM/dle Attachments J. B. Hopkins, NRC Senior Project Manager cc:

J. B. Martin, Regional Administrator, NRC Region III S. Stasek, DB-1 NRC Senior Resident Inspector Utility Radiological Safety Board 1

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bocket Number 50-346 License Number NPF-3 Serial Number 2167 e

i Listing of Submittal Contents Davis-Besse Unit 1 USAR Section 17.2, Quality Assurance-Program for Station Operation, Pages Affected by Proposed Changes Evaluation of Proposed Quality Assurance Program Reductions R

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Docket Number 50-346 4 ~

License Number NPF-3 Serial Number 2167 Page 1 Note The attached marked up USAR Section 17.2 includes several changes made prior to the proposed change of Quality Assurance to Nuclear Assurance.

The elimination of the Manager - Quality Systems occurred in October 1992 (reference:

USAR Change Notice (UCN)92-081). The responsibilities of the Manager - Quality Systems were divided among the remaining Quality Assurance Sections (Quality Verification and Quality Control). This change did not reduce commitments identified in the Quality Assurroce Program. Another change that was made eliminated the day-to-day, line quality review of specification and modification packages performed by the Engineering Assurance Unit (reference: UCN 92-058). This change was approved by the NRC on i

October 30, 1992 (Toledo Edison Log 1-2721). The remaining Engineering Assurance functions (i.e., assessment of engineering activities and products and plant chemistry issues) have been assimilated into the Quality Assessment Section (reference UCN 93-044). This change did not reduce commitments identified in the Quality Assurance Program.

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Docket Number 50-346 License Number NPF-3 Serial Number 2167 Page 2 ose non pl y cts 3vtante rel&d o

C 00' 17.2.1.4 Toledo Edison Nu,lEear Group 7'

NUC. LEAR 14 DIRECTOR - Q"ALITY ASSURANCE Noe esc l1 The Director - -Qu ity Assurance reports to the Vice President - Nuclear and is responsibis for the development, maintenance, and monitoring of the Nuclear 14 Quality Assurance Program. The Director is also responsible for advising the PlantManagerandcognizantcorporatemangegt,Assuranceisindependent l14 of the Quality Assurance Program's effectiveness. The Director y ---.7 from cost and scheduling considerations when opposed to safety considerations.

1 and is free of non-QA related dutiesf. He is authorized to identify quality probler.s initiate, recommend, or provide solutions, through l9 designated channels: verify implementation of solutions; and verify l1 cogrmancetoestablishedqualityrequirements. The Director -

l9 Q.-. 8 ' Assurance has the authority to suspend (stop work) any activity.

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except reactor operation, not in conformance with specified requirements 1

and/or provisions of the HQAM. Conditions adverse to quality that appear to warrant suspension of reactor operation, including startup or power g

stion are immediately reported to the Plant Manager. The Director Assurance is responsible for the ad, equate staffing of the 14 Assurance Department to encure that the requirements of the NQAM are effectively implemented.

1 MANAGER - QUALITY CONTROL 9

The Manager - Quality Control repor'ts to the Director - Quality Assurance and l14 i

is responsible for managing the Quality Control staff in the quality review.

!1 inspection, and examination of plant structures, systems, and components 14 within the scope of the Nuclear Quality Assurance Program to assure compliance to procedural, drawing, and engineering specification requirements. This responsibility includes the inspection of welding to l

verify it meets ASME National Board, and State of Ohio requirements in 1

addition to coordinating the activities of the Authorized Inspection Agency to ensure Code compliance.

Insert O 17.2 4 REV 16 7/92 4

Docket Number 50-346 License Number NPF-3 Serial Number 2167 Page 3 Insert A The Director - Nuclear Assurance is also responsible for directing the activities of independent safety engineering, engineering assurance and the review of external information and plant operations assessments.

The Director - Nuclear Assurance is responsible for managing support services associated with procedure control, records management and document control.

Insert B The Manager - Quality Control is also responsible for development and i

maintenance of the ASME Quality Assurance Manual and Quality Control l

and selected Nuclear Assurance Department' Procedures. The Manager -

Quality Control is also responsible for review of all corrective action documents for close-out, review of selected site procedures, receipt inspections, vendor surveillances and review of vendor supplied i

documentation, and Quality Control Staff training. The Manager -

Quality Control is also responsible for providing technical expertise onsite

^.o allow for systematic and independent assessment of plant i

activities by the independent safety engineering function. Additional responsibilities include surveillance of plant operations and maintenance activities to provide independent technical verification that these activities are performed correctly, and investigation of plant incidents which may affect the underlying assumptions in the USAR Accident Analysis.

The Manager - Quality Control is also responsible for the review of all external information received in support of l

improved performance and reliability and for plant operations j

assessments.

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Docket Number 50-346 License Number NPF-3 D-B Serial Number 2167 Page 4 9

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MANAGER - QUALITY "ERITICATION p ssessmen$

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WeMr The Manager - Quality.erification reports directly tof the Director

-Guelity-l14 Assurance and is responsible for managing the Quality 7 rificeticr. staff in the performance of internal and celected external OA audits, and for QA 8

surveillance of station operations.

l ]Enserf C l "ANAG n - 0"ALITY SYSTC:S 9

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-0 lity stems r ports d rectly o the recto - Qual y l14 l

A ouran and s resp nsible r supe ising e Qual ty Sys ms Sta i

sctivi les v thin t Quali System anager s area f resp nsibil y ine de.

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• velo ent a revisi of th Nucles and AS Qual y Assu nce M nuals an Quali y Assu nee De rtment rocedur s, Int -depar ent Pr cedur Revie,

9 C rect <e Act n Docum t Clos e, Qua ty Ass ance partme.

Trai ng, uali Trend g and alysis, endor udits/S rveill.ces, R iev a d Appr val of V dor 0 lity As urance P ograms rocedu s, mai tainin the A roved Ve or Lis,, Recei Inspec on, a Vendor uppli Docum tatio Revie.

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Docket Number 50-346

• I License Number NPF-3 Serial Number 2167 Page 5 Insert C

- The Manager - Quality Assessment is also responsible for development l

and maintenance of Quality Assessment and selected Nuclear Assurance

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Department Procedures, review of inter-department procedures, selected j

site procedures, the review and approval of Vendor Quality Assurance Programs and Procedures, performance of vendor audits, review of selected procurement documents, and control of the approved vendors l

list. The Manager - Quality Assessment is also responsible for the development, maintenance and implementation of the trending and analysis program and Quality Assessment staff training.

The Manager -

Quality Assessment is also responsible for the independent assessment l

of engineering activities and products, and review and evaluation of plant chemistry and radiochemistry issues.

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Manager - Quality Services i

The Manager - Quality Services reports to the Director - Nuclear i

Assurance and is responsible for the development and maintenance of the l

?!uclear Quality Assurance Manual, managing support services associated

~i with quality and non-quality records, document control, inter-department procedure related activities and administrative services.

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Docket Number 50-346 License Number NPF-3 1

Serial Number 2167 Page 6 D-B MANAGDI - pdEPD4DDTT SAILTI DUJ[TIRI!E l9 The ager - Inde >ndent sa ty Engin ring rep ts direct to the ' ce 9

Pre dent - Nuc ar, and i responsi e for pr iding te ical exp tise 9

-site to al v for sys ematic an independ

.t assessm t of pla 6

activities. Addition responsi ities i ude surv llance o plant 5

operatio and main ce act sties to rovide in pendent chni-5 cal ve ication at these tivities re perfo correc y and in s-5 tiga on of pl incident

.*hich ma affect th underlyi assumpt' ns in 5

th USAR Acci t Analys The I Departm functio inde ently from 8

her Nucle Group ac+ vities.

6 COMPANY NUCLEAR REVIEV BOARD The Company Nuclear Review Board (QiRB) is responsible for providing an i

independent review and audit of activities affecting quality to assure itself that Davis-Besse is being operated and maintained in compliance vith the Nuclear Quality Assurance Program and the Operating License. The a

nature of Q4RB activities include the monitoring and review of functions 5

and problems pertaining to nuclear safety. The Chairman of the QiRB is I

responsible for providing a QiRB Charter which meets the requirements of Section 6 of the Technical Specifications.

STATION REVIEV BOARD i

The Station Review Board (SRB) is responsible for the review of Plant Admin-1 istrative procedures, data, and deficiencies related to nuclear safety as 1

identified in the SRB Charter. The SRB may, as it determines necessary 7

direct investigations by Station personnel of facility activities to assure 1

that these activities have been, are being, and vill be performed in 1

accordance with approved vritten procedures. Generally, the SRB is 1

concerned with the nuclear safety related aspects of facility operation and 7

coordinates its activities with Quality Assurance to satisfy the OA 1

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requirements for facility operation. The Chairman of the SRB is responsi-1 ble for providing an SRB Charter which meets the requirements of Section 6 1

J of the Techni.21 Specifications.

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Docket Number 50-346 k License Number NPF-3 Serial Number 2167 Page 1 10CFR50.54 EVALUATION FOR UCN 93-032, REVISION 01 (EVALUATION OF PROPOSED OUALITY ASSURANCE PROGRAM REDUCTIONS) { r PROPOSED CHK.4GES The proposed changes to the Updated Safety Analysis Report (USAR) 3 Chapter 17.2, Quality Assurance Program for Station Operation, are shown on the attached marked up pages of Section 17.2.1.4, including Figure 17.2-1, (Toledo Edison Nuclear Group) and are revisions to previous UCNs 93-028, 93-032 and 91-044. Description of Change 1 (Pages 17.2-4, 17.2-5 and 17.2-11a and b) A) Modify the phrase "and is free of non-0A related duties..." by adding the clarification of: ...except for those non-0A related functions of the Manager Quality Services." B) Transfer the responsibilities for "t'e review of all external information received in support of improved performance and reliability and for plant operations assessments" to the Director - Nuclear Assurance (through the Manager-Quality Control) from the Manager - Regulatory Affairs. C) Change the title of Manager - Plant Services to Mcnager - Quality Services and shift reporting of the Manager - Quality (Plant) Services to the Director - Nuclear Assurance from the Director - Nuclear Services. Transfer the non-0A functions cf " site-vide procedure control, records management, document control, and administrative services" to the position of Director - Nuclear Assurance (through the Manager - Quality i Services). i Description of CL,acc Number 2 (Pages 17.2-4 and 17.2-11c) Shift the responsibilities for " independent safety engineering" to the position of Director - Nuclear Assurance (through the Manager - Quality Control) from the deleted position of the Manager - Independent. Safety Engineering presently reporting directly to the Vice President - Nuclear and presently functioning independently from other Nuclear i Group departments. These responsibilities include "providing technical expertise onsite to allow for systematic and independent assessment of plant activities" and " surveillance of plant operations and maintenance activities to provide independent technical verification that these activities are performed correctly, and investigation of plant incidents which may affect the underlying assumptions in the USAR Accident Analysis". l l i l 1 ] ~

Docket Number 50-346 . License Number NPF-3 Serial Number 2167 Page 2 Reason for Changes To support the Centerior Energy reorganization. j i To allow the Director - Nuclear Assurance to assume other i responsibilities for performing additional quality assurance and some i non-quality assurance functions as described above. .l 8 Effect of Change 1 .) A) ELIMINATION OF "NON-0A DUTIES" RESTRICTION ON OA DIRECTOR l Under the proposed Davis-Besse Nuclear Power Station reorganization, l the position of Director - Nuclear Assurance (presently the position of Director - Quality Assurance) vill no longer be " free of non-0A related duties" as stated in USAR Section 17.2.1.4 of the Quality t Assurance Program for Station Operation. The phrase "and is free of non-0A related duties" is not a requirement of 10CFR50 Appendix B, Quality Assurance Criteria for. Nuclear Power Plants, Criterion I - Organization. The requirements of Criterion I do not preclude persons and organizations performing l quality assurance functions from performir.g non-quality assurance 1 functions when such functions do not affect the safety related' functions.f structures, systems, and components. j The basis for concluding that the new position of Director - Nuclear f Assurance, with the modification.of non-0A related duty [ restrictions, vill continue to satisfy the requirements of 10CFR50 i Appendix B follows: Under provisions of 10CFR50 Appendix B, Criterion I, persons and organizations performing quality assurance functions must have sufficient authority'and organizational freedom to identify quality i problems; to initiate, recommend, or provide solutions; and to verify implementation of solutions. It also requires those persons j and organizations performing quality assurance functions to report l to a management level such that the requireo authority and organizational freedom, including sufficient independence from cost and schedule when opposed to safety considerations, are provided. t The proposed changes and USAR 17.2.0, Policy, establish sufficient authority and organization freedom, and sufficient independence from cost and schedule when opposed to safety considerations for the quality assurance function and continue to satisfy the provisions of 10CFR50 Appendix B, Criterion I. j B) TRANSFER OF "0PERATIONS EXPERIENCE ASSESSMENT (0EAP)" ACTIVITIES TO. f NUCLEAR ASSURANCE The Director - Nuclear Assurance assumes the responsibilities for I "the review of all external information received in support of i improved performance and reliability and for plant operations assessments" (through the. Manager - Quality Control) from the

Docket Number 50-346 j =i License Number NPF-3 ~ ' Serial Number 2167 l Pagt 3 I! Manager - Regulatory Affairs. The transfer of these OEAP activitbss with ISEG activities (See Effect of Change 2) to Noclear Assurance l (Quality Control) consolidates responsibility for similar overviev activities. The basis for concluding that this organizational change regarding the new position of Director - Nuclear Assurance continues to satisfy the requirements of 10CFR50 Appendix B follows: j This additional responsibility provides activities which are considered to be an enhancement of quality assurance functions described in 10CFR50 Appendix B, Criterion I. The audit and surveillance activities of the Manager - Quality Assessment vill remain independent of these functions just as they have in evaluating existing Quality Control functions. C) TRANSFER OF " PLANT SERVICES" ACTIVITIES TO NUCLEAR ASSURANCE l The Director - Nuclear Assurance (through the Manager - Quality l Services) assumes the non-0A functions of site-vide procedure control, records management, document control, and administrative services from the deleted positions of Director - Planning and 1 Support and Manager - Engineering Assurance and Services. The basis for concluding that this organizational change regarding F the new position of Director - Nuclear Assurance continues to i satisfy the requirements of 10CFR50 Appendix B follows: These additional responsibilities are considered to be non-quality assurance functions which.do not affect the safety related functions of structures, systems and components. The audit and surveillance activities of the Manager - Quality Assessment will remain independent of these functions just as they have in evaluating -i existing Quality Control functions. j l Effect of Change Number '2 TRANSFER OF "INDEPLdDENT SAFETY ENGINEERING (ISEG)" ACTIVITIES TO NUCLEAR ASSURANCE The Director - Nuclear Assurance (through the Manager - Quality t Control) assumes the responsibilities for " independent safety engineering" from the deleted position of the Manager - Independent i Safety Engineering presently reporting directly to the Vice President - Nuclear and presently functioning independently from i other Nuclear Group departments. The transfer of these ISEG activities withc0EAP activities (See Effect of Change 1B) to Nuclear Assurance (Quality control) consolidates responsibility for similar j overviev activities. 3 The function of independent safety engineering is neither a Technical Specifacation nor a 10CFR50 Appendix B requirement for Davis-Besse. .l

Docket Number 50-346 License Number NPF-3 ~ Serial Number 2167 Page 4 Under the proposed change, the Manager - Quality Control, who vill report 'o the Director - Nuclear Assurance, vill have responsibility for v.. function of independent safety engineering. The independent safety engineering function vill no longer be a separate area which reports directly to the Vice President - Nuclear, as previously described. The level of independence for independent safety 1 engineering activities is established in USAR Section 17.2.0, Policy. To adequately fulfill assigned responsibilities of the Director - Nuclear Assurance, the policy allows the Director - Nuclear Assurance access to the Chairman (President and Chief Executive Officer) if the need for such access exists. The organizational freedom described is considered to be sufficient for independent safety engineering activities. The basis for concluding that this organizational change regarding the new position of Director - Nuclear Assurance continues to satisfy the requirements of 10CFR50 Appendix B follovs: These additional responsibilities provide activities which are considered to be an enhancement of the quality assurance functions described in 10CFR50 Appendix B, Criteria I, and are appropriately organizationally structured for that purpose. The audit and surveillance activities of the Manager - Quality Assessment vill remain independent of these functions just as they have been in evaluating existing Quality Control functions. i BASIS FOR CONCLUSION THAT CHANGES CONTINUE TO SATISFY THE CRITERIA 0F 10CFRSO APPENDIX B In summary, the Director - Nuclear Assurance vill have the following functional responsibilities in addition to the quality assurance responsibilities presently held: independent safety engineering, the review of external information, plant operations assessments, site-wide procedure control, records management, document control, and administrative services. The basis for concluding that the organization changes, identified above, continue to satisfy the requirements of 10CFR50 APPENDIX B, is as follows:

1) The proposed changes vill not diminish or reduce the effectiveness of the quality assurance functions as currently described.

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Docket Number 50-346 License Number NPF-3 3 4 ' Serial Number 2167 i ] Page 5

2) The changes continue to provide sufficient authority and organizational freedom of the quality assurance functions to identify quality problems and sufficient independence from cost l

and schedule when opposed to safety consid& rations.

3) The changes provide an independent organization to function in a strong overview capacity, utilizing both compliance and performance based approaches.

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4) The changes provide an overview function with a high level of expertise and management involvement in areas such as:

traditional quality assurance activities and overviews and assessments of engineering activities, operational activities, and industry experience. l

5) The audit and surveillance activities of the Manager - Quality Assessment vill remain independent of all these additional functions just as they have in evaluating existing Quality Control functions.

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6) The Quality (Nuclear) Assurance department is periodically assessed by the Company Nuclear Review Board (CNRB) and by external organizations such as NRC INPO, and the Joint Utility Management Assessment (JUMA) team.

Similar assessments of these additional Nuclear Assurance functions vill be periodically performed. This reorganization is perceived to enhance Toledo Edison's goals in providing safe and reliable operation of the Davis-Besse Nuclear Power Station. I s 5 I i 4 i I 1 1}}