ML20046C627
| ML20046C627 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom, Limerick  |
| Issue date: | 08/04/1993 |
| From: | Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9308110248 | |
| Download: ML20046C627 (17) | |
Text
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PHILADELPHIA ELECTRIC COMI%NY 10CFR50.54(a)(3)(1)
NUCLEAR GROUP HEADQUARTERS 955-65 CHESTERBROOK BLVD.
WAYNE, PA 19087-5691 (215) 640wn)
STATION SUPPORT DEPARTMENT Docket Nos. 50-277 278 50-352 50-353 License Nos. DPR-44 DPR-56 NPF-39 NPF-85 August 4, 1993 U.S. Nuclear Regulatory Commission Attn:
Document Control Desk Washington, DC 20555
SUBJECT:
Peach Bottom Atomic Power Station, Units 2 and 3 Limerick Generating Station, Units 1 and 2 Request for Approval to Change the Quality Assurance Program Description by Transferring the In-Line Reviews of Procurement Documents and Specifications
Dear Sir:
This letter is submitted in accordance with 10CFR50.54(a)(3), which requires prior NRC approval for any change which reduces the commitments in a previously accepted Quality Assurance Program description.
Philadelphia Electric Company (PECO) is proposing to transfer the responsibility for J
performing in-line reviews of procurement documents and specifications from the. Nuclear Quality Assurance (NQA) organization to the Line organizations.
In that these reviews will no longer be performed by the independent NQA organization,.this proposed change could be viewed as a reduction in commitment in the NRC approved Peach Bottom Atomic Power Station (PBAPS) and.
i Limerick Generating Station (LGS) QA Program Descriptions.
Accordingly, we j
are requesting NRC approval of this change in accordance with j
These commitments are specifically described in Appendix D of the PBAPS Updated Final Safety Analysis Report (UFSAR) and Chapter 17.2 of the LGS UFSAR.
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U.GJ Nuclear Regulatory Commission August 4, 1993 Document Control Desk Page 2 of 3 This commitment has been in effect since the design and construction phases of PBAPS and LGS. Considerable NQA resources continue to l
be expended in performing these reviews.
As our Nuclear Group organizations restructure and assume roles and responsibilities to increase their accountability for the total quality of their work, we have determined that i
assigning this responsibility to the line organization will result in more efficient and effective use of resources.
Established processes and procedures require the requisitioning department to determine the technical requirements (which include the quality and other requirements) for each safety related procurement.
Procedures for the preparation of procurement documents for safety related material (including off-site repair and calibration of equipment) require a detailed, documented evaluation and verification of the requirements.
The evaluation i
process was developed with NQA input, to address the technical (including quality) requirements.
Implementation of this process has been so successful, and the knowledge and capability of requisitioning department personnel to establish appropriate technical, as well as quality i
requirements, has become so enhanced that the NQA review has become redundant.
To facilitate this transfer, NQA will work closely with the line organizations to assure that equivalent review criteria are established which will assure that the quality of procurement documents and specifications remains consistent.
Indoctrination and training in the appropriate quality concepts will be implemented to assure that personnel are capable of performing the reviews.
i The proposed changes to the QA Program Descriptions are provided in Attachments 1
and 2
respectively.
Since approval of this proposed description change would permit us to redirect the man-hours that would be i
expended to support other NQA transitional efforts, we request the NRC's j
prompt attention to this matter.
If you have any questions or need additional information, please contact us.
Very truly yours, l
04-Georg A. Hung r.
l Director, Licensing Attachments cc:
T. T. Martin, Administrator, Region I, USNRC w/ attachments B.
S. Norris, USNRC Senior Resident Inspector, PBAPS w/ attachments N.
S. Perry, USNRC Senior Resident Inspector, LGS w/ attachments L.
Bettenhausen, Chief, Operations Branch, Region I, USNRC i
Proposed Changes to the Quality Assurance P> -gram Description for Limerick Generating Station Units 1 and 2 i
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LGB UFSAR i.
Document conditions adverse to quality resulting from QV i
activities and verify corrective action.
j.
Provides independent verifications in mechanical, electrical, I&C and welding disciplines.
k.
Provides visual, liquid penetrant, magnetic particle, and i
ultrasonic inspections.
1.
Coordinates NDE activities with appropriate piant 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 following responsibilities:
a.
Provide administrative supervision and technical direction of the activities of the Quality Support Section.
b.
Consult with the Quality Verification Superintendent, Technical Monitoring Superintendent, Quality Assurance Superintendent and the site Quality Division Manager, on significant problems affecting quality.
Ensure that personnel involved in performing NQA Quality
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c.
Support activities are trained and qualified.
d.
Review and coordinate revision of NQA Procedures.
Review of selected Station Administrative Procedures and c.
Implementing Procedures.
f.
Review and approval of procurc cnt decurente end l
technical receipt inspection documents for safety related items and services.
Review NCRs for conditions adverse to quality.
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h.
Tracking and trend analysis of Verification and Monitoring Activity reports and CARS.
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Document conditions adverse to quality identified during l
Quality Support activities.
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Appropriate test, audit, and inspection requirements.
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Appropriate requirements for fabrication such as special process procedures.
1.
Appropriate requirements for handling, storage, packaging, and shipping.
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Lower-tier procurements.
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Any additional documentation requirements.
17.2.4.2 To the extent necessary, procurement documents shall require 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.
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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.
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17.2.4.3 Requisitions for nuclear safety-related items shall clearlyindicate that the request
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is for " nuclear safety-related" items.
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 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 procurement document. The member shall also determine any special controls to be applied such as vendor controls, hold points, and 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.
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LGS UFSAR 17.2.1.2.3.2 Limerick Independent Safety Engineering Group The Limerick Ind,ependent safety Engineering Group (ISEG) composition and responsibilities are described in Section 13.4.5.
17.2.1.2.3.3 Performance Assessment Section The Performance Assessment Section is under the supervision of a l.
Superintendent who reports to the General Manager, Nuclear Quality Assurance. Performance Assessment is responsible for independently evaluating PEco's nuclear activities with particular emphasis on assessing and improving plant performance. The assessments will be conducted to determine if appropriate nuclear programs have been developed, implemented, and are functioning in a manner to achieve excellence.
These assessments will be based on sources of I
information such as monitoring of plant performance trends, QA and Quality Verification reports, reports from the Independent Safety Engineering Groups, trend analysis, observation of plant condition and activities, the conduct of internal evaluations and special assessments-anci. reviews.- The Superintendent will_. report on these subjects to the Nuclear Review Board, the Senior-Vice President, Nuclear, and the three Vice Presidents through the General Manager, l
Nuclear Quality Assurance.
17.2.1.2.3.4 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 four sections:
Quality Engineering, Vendor Evaluation, NDE Support and Administration; and a Training Coordinator. The Manager, Corporate Nuclear Quality, is responsible for all Corporate Nuclear Quality Division activities.
This includes:
i a.
Manuals and procedures.
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Vendor audits and surveillances.
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Training.
d.
Tr;curtzent 0:ntr:1:;
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Oversight of the quality activities of Nuclear Engineering and Services.
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.
17.2-17 Rev.2 July /92
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Single point of accountability for all Corporate Nuclear Quality (CNQ).
17.2.1.2.3.4.1 Quality Engineering Section The Quality Engineering Section is under the supervision of a Superintendent who reports to the Manager, Corporate Nuclear Quality Division.
The Superintendent's responsibilities include:
Scheduling and performance of technical and/or a.
performance based internal audits.
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Modifications interface.
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Verification of NRC correspondence (as requested).
Engineering programs overview expertise.
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17.2.1.2.3.4.2 Vendor Ev'aluation Section The Vendor Evaluation Section is under the supervision of a Superintendent whc reports to the Manager, Corporate Nuclear Quality Division.
The Superintendent is responsible for:
Providing ad.ministrative direction for the perforshnce of a.
vendor evaluation activities including audits, surveillance and commercial grade surveys.
Directing the perfornance of contractor security screening b.
audits and special services audits.
Maintaining the Evaluated Vendors List.
c.
d.
Technical direction for the Nuclear Fuel QA Progran.
1 The Audit Program Will involve compliance-based, performance-based, and/or technical-based audits or a conbination thereof, as Where it is practical and appropriate (e.g.,
appropriate.
operational audits), the audits will be primarily perfor=ance-based and/or technical-based audits.
17.2-13 Rev.2 July /92
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LGS UFSAR 17.2.4 PROCUREMENT DOCUMENT CONTROL 17.2.4.1 t
Measures shall be established and documented to ensure.that applicable regulatory requirements, design bases, and other requ rements which are necessary to assure i
adequate quality, are included or referenced in the documents for procurement of items and services. Changes in procurement documents shallbe subject to the same i
degree of control as was utilized in the preparation of the original document, as I
described herein.
The documents used for procurement shall specify appropriate requirements for:
Submittal of drawings, specifications, procedures, and plans to PECo.
a.
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 submittalle.g., prior to shipment) and the purpose of submittal (e.g., review, approval, or information) shall be specified.
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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
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Reporting and dispcsition of nonconformances from procurement
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requirements when the vendor's proposed disposition is "use-as-is" or
" repair. "
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Submittal of documentation that identifies the purchased items and the j
specific procurement requirements (e.g., codes, standards, and specifications) met by the item.
l Submittal of documentation identifying any procurement requirements g.
that have not been met.
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Design basis technical requirements, including applicable regulatory l
requirements.
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Appropriate material and component identification requirements.
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17.2-31
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 r.eview process and are referenced in procurement documents.
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?!uc! car Qunlity 1.ccurance percenncI c"" rcr:ct and apprcre the document: "hich -
-define the Q *. prcyc= cnd quality requirenent: t cccure that cuch req 1drc= ente-g crc correctly
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and inc7 xt:b!: and that edcquete-
$"s m n eceptancef reje ctinn criter:c arc dcfine d.
Thic pcrmit: rcrificc+icn that th -
document: to be uced for procuxncnt have been prepared, rer:ct:cd, nnd c;; raved
--in accordance "ith the Q.'. pnpar 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 i
f to the issuance of changes.
17.2.4.9 Purchase orders shall be issued to suppliers whose quality assurance programs have been evaluated for adequacy, or other appropriate measures shall be defined to assure quality.
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.
17.2.4.9.2 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 commercialitems such as price, quantities, schedule, F.O.B. terms, etc.
Prior approval is required from the responsible organization for cases where the requisitioning source is not the PECo organhation responsible for the technical and quality aspects of the item or service.
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17.2.4 Procurement Document Contro_1 17.2.4.1 Heasures are established in accordance with PBAPS Administrative Procedures to control the preparation, approval and issuance of procurement documents.
1/.2.4.1.1 Material, parts, and services shall be procured in accordance with Administrative, Purchasing Department and Materials Section Procedures.
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-44 Administrative Procedures require that alPro; r;;cr.t Engi cor',; Crc,up determine the technical and quality assurance requirements for a " Safety-Related" item. The member Irtcurc cnt "nginc.cr'n; Crcup determines the applicable specification, drawings, details, and code requirements to be applied to the procurement document and also determines special controls to be applied, such as:
vendor controls, i
hold points, tests to be performed, test acceptance er rejection criteria, sub-vendor controls, vendor check points, test data,-test results, special labeling, storage instructions, requirements for reporting nonconformances, shipping instructions, receipt controls, and QA documentation requirements.
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-Procedures are established for the review of procuremen to determine that quality requirements are correctly stated, inspectable and controllable; there are adequate acceptance and i
rejection criteria; and procurement documents have been prepared, reviewed and approved in accordance with QA program requirements.
The review and concurrence of the adequacy of quality requirements stated in procurement documents is performed by_, qualified personnel.
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. s 17.2.4.4 Q-Listed material, parts, equipment, and services identified with a QS procurement level shall te purchased from vendors or contractors who are on the PEco Evaluated Vendors List.
17.2.4.5 Nuclear Quality Assurance is responsible for establishing, maintaining, revising, and issuing an " Evaluated Vendors List" for PECo Nuclear Power Plants.
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17.2.4.6 Nuclear Engineering procurement dacuments for modifications shall be controlled.
17.2.4.7 The-Mate-tal: S:ctier and Purchasing Department shall-sn4f-i process approved requisitions in accordance with PECo procurement procedures and policies.
i 17.2.4.7.1 The Purchasing Department shall not alter the technical information or quality assurance requirements on a requisition l
of any procurement classification identified as QS, QV, QD or NX item witt'at, specifically requested prior, written approval of the requisitioning organization.
17.2.4.8 The procurement document for QS and QV items shall include a provision for the right-of-access to vendor facilities for i
inspection or audit purposes.
17.2.4.9 Procurement documents shall be maintained in accordance with Section 17.2.17.
17.2.5 Instructions, Procedures, and Drawings 17.2.5.1 Activities associated with the implementation of the Nuclear Quality Assurance Program shall be described and accomplished in accordance with appropriate instructions, procedures, and drawings. Administrative procedures shall be written for D.11-26 Rev. 10, 07/92 1
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Procedures are estab)ished for the review of procurement documents to determine that quality requirements are correctly stated, inspectable and controllable; there are adequate acceptance and rejection criteria; and procurement documents have been prepared, reviewed and approved in accordance with QA program requirements.
The review and concurrence of the adequacy of quality requirements stated in procurement documents is performed by qualified personnel.
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Proposed Changes to the
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Peach Bottom Atomic Power Station Units 2 and 3
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Provide independent verifications in mechanical, eletrical, I&C and welding disciplines.
11.
Provide visual, liquid penetrant, magnetic particle and ultrasonic inspections.
12.
Coordinate NDE activities with appropriate plant technical and craft suoervision 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 following responsibilities:
1.
Provide administrative supervision and technical direction of the activities of the Quality Support Section.
2.
Consult with the Quality Verification Superintendent, Technical Monitoring Superintendent, Quality Assurance Superintendent and the Site Quality Division Manager on rignificant problems affecting quality.
3.
Ensure that personnel involved in performing NQA Quality Support Activities are trained and qualified.
4.
Review and coordinate revision of HQA Procedures.
5.
Review of selected Station Administrative Procedures and implementing procedures.
6.
Review and approval of precur :nt decurer.t: and l
technical receipt inspection documents for safety related items and services.
7.
Review HCRs for conditions adverse to quality.
8.
Tracking and trend analysis of Verification and Monitoring Activity reports and CARS.
9.
Document conditions adverse to quality identified during Quality Support activities.
D.11-7 Rev. 10, 07/92
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PBAPS Peach Bottom Indeoendent Safety Encineerir.a Group i~.c.. 2.3.2 The Peach Bottom Independent Safety Engineering Group (ISEG)
- mpos't'e-and responsibilities are described in Section 13.8.6 17.2.1.2.3.3 Perf ormance Assessment Section The Perf ormance Assessment Section is under the supervisiori of a Superintendent, who reports to the General Manager, Nuclear Quality Assurance.
Performance Assessment is responsible for independently evaluating PECo's nuclear activities with particular emphasis on assessing and improving plant-performance. The assessments will be conducted to determine if appropriate nuclear programs have been developed, implemented, and are functioning in a manner to achieve excellence. Tnese assessments shall be based on sources of information such as monitoring of plar. performance trends, QA and Quality Verification reports, from the Independent Safety
. )
Engineering Groups,' trend analysis, observation of plant condition and activities, the conduct of internal evaluations
'and special assessments and reviews. The Superintendent will report on these subjects to the Nuclear Review Board, the l
Senior Vice President, Nuclear, and the three Vice Presidents through the General Manager, Nuclear Quality Assurance.
17.2.1.2.3.4 Corporate Nuclear Ouality 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 four sections:
Quality Engineering, Vendor Evaluation, NDE Support, and Administration; and a Training Coordinator.
The Manager, Corporate Nuclear Quality, is responsible for all Corporate Nuclear Quality Division activities. This includes:
1.
Manuals and procedures, 2.
Vendor audits and surveillances, 3.
- Training, 4.
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PBAPS 5.
Oversight of the quality activities of Nuclear Engineering and Services, 6.
Identification of specific and prpgrammatic deficiencies and tracking of thesh items until they are fully resolved, 7.
Performing trend analysis, 8.
Conducting internal audits at the corporate offices, 9.
Single point of accountability for all Corporate Nuclear Quality (CNQ).
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17.2.1.2.3.4.1 Quality Engineerino Section The Quality Engineering Section is under the suparvision of a Superintendent who reports to the Manager, Corporate Nuclear 1
Quality Division. The Superintendent's responsibilities include:
1.
Scheduling and performance of technical and/or performance based internal audits, 2.
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Modifications interface, 4.
Verification of NRC correspondence (as requested),
5.
Engineering programs overview expertise, 17.2.1.2.3.4.2 Vendor Evaluation Section i
The Vendor Evaluation Section is under the supervision of a Superintendent who reports to the Manager, Corporate Nuclear Quality Division. The Superintendent is responsible for:
1.
Providing administrative direction for the performance of vendor. evaluation activities including audits, surveillance and commercial grade surveys.
2.
Directing the performance of contractor security screening audits and special services audits.
D.11-10 Rev. 10, 07/92
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