ML20054F393
| ML20054F393 | |
| Person / Time | |
|---|---|
| Site: | Dresden, Byron, Braidwood, Quad Cities, Zion, LaSalle, 05000000 |
| Issue date: | 06/06/1982 |
| From: | COMMONWEALTH EDISON CO. |
| To: | |
| Shared Package | |
| ML20054F388 | List: |
| References | |
| CE-1-A-ERR, CE-1-A-R21-ERR, NUDOCS 8206160236 | |
| Download: ML20054F393 (20) | |
Text
- - -.
i assurance activities.
The NSSS Supplier furnishes technical and Quality Control assistance for on-site activities relating to the NSSS.
On-site contractors' quality assurance programs are 21 independently evaluated by Edison Quality Assurance.
Pre-service Testing Pre-service testing, consisting of preoperational and start-up testing, is controlled by Edison.
The Architect Engineer and the NSSS Supplier furnish rough draft test procedures to Edison.
Based on these, a final draft is written by Edison.
This final draft is subjected to internal Edison evaluation and evaluation by the Archi-tect Engineer or the NSSS Supplier as appropriate.
The tests are managed and performed by Edison with technical assistance from the NSSS Supplier as appropriate.
The evaluation of the test results is performed by Edison and confirmed by independent internal Edison evaluations.
Further independent evaluations by the Architect Engineer or the NSSS Supplier are performed as required by Edison.
j Operations 4
Commonwealth's managerial and administrative control of the Quality Assurance Program for operating nuclear stations, as illus-
~
trated in Figures 1-0, 1-1, and 1-6 includes review and approval of procedures by the personnel described in this document.
Quality Procedures and revisions thereto for the Company Manual are concurred with by the principally involved departments.
I The Director of Quality Assurance (Operating) reporting to the Manager of Quality Assurance, verifies that the Quality Procedures for Operating contained in the Company Manual or Station Quality l
Procedures comply with the policy described in this document.
Similarly, the Supervisor Quality Assurance (Maintenance) verifies that the Quality Procedures for malaten-ance, modifications, 1
in-service inspection and Stores activities comply.
The Manager of Quality Assurance directs the quality assurance activities covering operations and approves the Quality Assurance Procedures covering operating, maintenance, modifications, in-service inspection and Stores activities for use in the Station.
i Station Procedures and instructions and revisions thereto for the Station Procedures Manual are reviewed and approved as provided in the Technical Specifications.
The station Quality Assurance Engineer or Inspector reporting to the Director of Quality Assurance (Operating) provides surveillance of the preparation and revision of the station operating procedures and instructions to assure compliance with the policies contained in the Quality Assurance Program.
The Quality Assurance Engineers or Inspectors l
for maintenance, reporting to the Supervisor Quality Assurance (Maintenance), provide surveillance of the -preparation i
i 1-4 bk kbOh O$bobo 0 6b/82 I
P PDR Commonwealth Edison
Dotted lines represent audit responsibility for verifying compliance with the procedures and instructions independent of the person or group directly responsible for performing the activities.
The specific responsibilities for the Quality Assurance Program are described in the following paragraphs.
1.1 General As assigned in the policy statement for the Corporate Quality Assurance Manual by the Chairman and President, the Vice Chairman of Commonwealth Edison Company has overall responsibility for the Quality Assurance Program covering the design, construction and operation of the Company's nuclear generating stations.
Similarly assigned, authority and responsibility is assigned to the Manager of Quality Assurance for quality assurance with respect to design, procurement, construction and operation if the Company's nuclear power stations.
Further, other authorities and responsi-bilities are as delineated in the organization section.
The Executive Vice Presidents, Vice President (Engineering);
Manager of Quality Assurance; Vice President Nuclear Operations; i
Vice President (Divisions); Manager of Station Construction; Manager of Projects and Vice President (Purchasing) are responsible for I
implementation of the Quality Assurance Programs as described herein.
1 The Manager of Projects directs the design, construction and pre-operations operating activities involving the project during the initial design and construction of the nuclear unit or for other specially established projects after the unit has been placed into operation.
The Project Managers reporting to the Assistant Man.ager of Projects and the Manager of Projects, are respons_ible for the 21 Project activities involving project engineering, construction, testing, and preoperational and start-up operations.
The Projects Department Engineering, Construction and Operation groups have line responsibility involving the project during the initial design, construction and preoperational operations of the nuclear unit.
The Project Engineering, Project Construction and Project Operation groups are formulated respectively from the Station Nuclear Engineering and Station Construction Departments and the Production Nuclear Division which have functional responsibility and control of the corresponding Projects Department organizations.
The Project Operation group for a respective unit shall. revert back to the Production Nuclear Division when an operating license becomes effective.
The Project Construction and Project Engineering groups shall revert back, respectively, into the Station Construction and Station Nuclear Engineering when the nuclear unit is placed into 1-6 Re v'. 21 6/6/82 i
Commonwealth Edison I
l
I 4
e 1.4.6 Director of Quality Assuranco (Operating) Continued the Divisicn Vice President and General Manager, Nuclear Stations, Director Nuclear Fuel Services and, 21 where applicable, the Vice President (Fuel & Budgets) of significant quality assurance questions and problems i related to fuel fabrication. The Director of Quality Assurance (Operating) has sufficient authority to identify problem areas and require corrsctive action.
1.4.6.1 Nuclear Fuel Fabrication Inspector The Nuclear Fuel Fabrication Inspector has the responsibility for surveillance of fuel fabrication at vendor's plant. He reports to l
the Director of Quality Assurance (Operating).
1.4.7 Supervisor Quality Assurance (Maintenance)
The Supervisor Quality Assurance (Maintenance) reports to the Manager of Quality Assurance and is responsible for administration of the Commonwealth Edison Company Quality Assurance Program Requirements and Procedures established for the maintenance modification', in-service inspection and Stores activities at Operating Nuclear Power Stations.
This Supervisor will regularly inform the Manager of Quality Assurance of significant Quality Assurance developments, activities and problem areas.
The Supervisor Quality Assurance (Maintenance) has sufficient authority to identify problem areas and require corrective action.
1.4.8 Station Quality Assurance Supervisor The Station Quality Assurance Supervisor reports to the Director of Quality Assurance (Operating) on quality assurance operating activities and to the Supervisor Quality Assurance (Maintenance) on quality assurance activities involving modifications, maintenance, in-service inspection and Stores activities for operating nuclear power stations.
The respective Quality Assurance Engineers or Inspectors assigned to the station report to the Station Quality Assurance Supervisor.
I.
The Quality Assurance Engineers or Inspectors for operating assigned to a station have authority and responsibility for the surveillance and audit of:
The preparation and revisicn of the station a.
procedures for administration and operations.
b.
Implementation of the Operations portion of the Quality Assurance program.
1-21 Rev.21 6/6/82 Commonwealth Edison
c.
The completion of documentation showing that the required inspections and tests were performed.
d.
The completion of reported corrective action.
The incorporation of approved engineering e.
changes into station operating procedures.
II. Quality Assurance Engineers and Inspectors for main-tenance, modification, in-service inspection and Stores activities assigned to the stations have authority and responsibility for surveillance and audit of:
a.
Implementation of the modification and mainten-ance portion of the Quality Assurance Program.
b.
The preparation and revision of the Station
' Procedures for the modification and maintenance.
The completion of documentation showing that the c.
required inspections and tests were performed for modification, maintenance and material receipts. He chall also review and approve receiving inspection documentation.
d.
The proper and satisfactory completion of modifi-cation, maintenance and reported corrective action. He shall also review and approve such completion and corrective action.
The incorporation of approved engineering changes e.
into maintenance and operating procedures.
f.
Completion of ASME Code requirements.
g.
In-service inspection and Stores activities.
h.
Adherence to Technical Specification require-ments where involved with modification, mainten-ance and in-service inspection activities.
1.5 Production Department Responsibilities 1.5.1 Production - Nuclear Division 1.5.1.1 Division Vice President and General Manager, 21 Nuclear Stations The Commonwealth Edison Company production stations are divided into two Production 1-22 Rev.21 6/6/82 Commonwealth Edison
Divisions - Fossil cnd Nucloor.
Tha Division 21 Vice President and General Manager in charge of each Division is responsible lor the safe and reliable operation and maintenance of the plant assigned to his division.
The Division Vice President and General Manager, 21 Nuclear Stations reports to the Vice President (Nuclear Operations) and has line responsibility for the administration, management and direction of all Production Department activities at operating nuclear stations.
During construction and preoperation operating activities, he has functional respcnsibility and control of Project operation activities and assumes operating responsibility when an operating license becomes effective.
He is responsible for implementation of the Quality Procedures for the Quality Assur-ance Program and for development of Station procedures for the Station Procedures Manual.
He is also responsible for obtaining and authorizing the use of services, or required liaison or interface with, other Commonwealth Edison Company departments such as: Accounting, Industrial and Public Relations, Purchasing, Engineering, Construction, Materials Analysis and Operational Analysis.
He is responsible for approval of requisitions for the procurement of services from vendors and contractors.
He provides liaison between Lae Regi,onal Nuclear Regulatory Commission's Director of the Office of Inspection and Enforcement and the Office of the Production Department.
He is responsible, through the Station Superintendent, for the management of each l
assigned power station.
This includes all activities such as, operation, maintenance and l
refueling, and authorization of modifications performed at the Station, compliance with all regulations and licenses, personnel selections, training and related activities.
He assigns responsibility for preparation and implementa-tion of the Station Procedures Manual to the Station Superintendent including the Maintenance Procedures.
The Division Vice President and General 21 Manager, Nuclear Stations coordinates the planning of each assigned station's 1-23 Rev.21 6-6-82 Commonwealth Edison
~
1.5.1.5.1 1ha Mactor Instrumant Machtnic The Master Instrument Mechanic is-responsible for maintaining and repairing instrumentation at the Station. His responsibility includes planning work, providing on-the-job training of instrument personnel, setting up instruments for tests, maintaining listing of calibrated instruments, arranging for the instrument maintenance work and its inspection to be performed and initiating requisi-tions for the procurement of instruments and parts from vendors and services from contractors.
The Master Instrument Mechanic reports to the Maintenance Assistant Superintendent.
1.5.1.6 Personnel Administrator The Personnel Administrator reports to the Superintendent and performs various personnel activities as assigned.
Reporting to him is the Training Supervisor.
1.5.1.6.1 Training Supervisor The Training Supervisor is respon-4 sible for the training and retraining of operating and main-tenance personnel.
His responsi-bility includes planning, sched-uling, preparing, presenting and documenting completion of training Courses.
1.5.2 Maintenance Manager - Nuclear Stations The Maintenance Manager is shown in Figure 1-6.
The Maintenance Manager reports to the Division Vice President and General Manager, Nuclear Stations and is responsible for functional direction of maintenance activities at nuclear stations including In-Service Inspection activities, special tool and equipment development, equipment and refueling outage schedules and contractor and vendor activities.
He is responsible for providing direction to the Maintenance Assistant Superintendent regarding day-to-day maintenance operations, forced outages, scheduled outages and refueling operations plus an effective maintenance program for ALARA radiation exposures.
1-28 Rev. 21 6/6/82 Commonwealth Edison
1.5.3 Opsrations Managar - Nuclocr Stctions The Operations Manager is shown in Figure 1-6.
The Operations Manager reports to the Division Vice 2*
President and General Manager, Nuclear Stations and has functional responsibility for operation of nuclear stations in a safe and efficient manner and in accordance with Company procedures, NRC Technical Specifications and governmental regulations.
His responsibilities include:
Providing direction to the Operating Assistant a.
Superintendent regarding day-to-day operation of station units.
l b.
Coordinating unit outages with Power Supply.
Reviewing station operating performance for c.
adherence to procedures, technical specifications and other governmental regulations.
d.
Reviewing the results of personnel performance investigations and follow-up on corrective actions.
Participating in personnel performance e.
investigations as assigned.
f.
Participating in station AIR meetings and followup as appropriate on corrective actions.
g.
Reviewing license event reports and deviation reports for trends, effects on other units and corrective action.
h.
Communicating common equipment and system problems among stations in a timely manner.
i.
Reviewing station response to NRC inspections and Quality Assurance audits for trends, corrective action, and follow-up on completion of commitments.
j.
Initiating and coordinating GSEP drills.
k.
Coordinating the implementation of nuclear security regulations.
1.5.4 Technical Services Manager - Nuclear Stations The Technical Services Manager is shown in Figure 1-6.
The Technical Services Manager reports to the Division Vice President ano General Manager, Nuclear Stations and 2 has functional responsibility for the Station Technical Staff organizations and work assignments.
He has responsibility for career planning of technical 1-29 Rev. 21 6/6/82 Commonwealth 5dison
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CHAIRMAN AND PRESIDENT I
MANAGER OF PROJECTS I
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ASSISTANT MANAGER OF PROJECTS PROJECT PROJECT PROJECT ttANAGER IIANAGER MANAGER DIRECTOR OF (BYRON NID (LA SALLE (RJHIRE)
SCHEDULING BRAIDWOOD COUNTY AfiD COST STATIONS)
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SUPERINTENDENT SUPERIIITENDENT l
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SITE QUALITY SITF. CONSTRUCTION SUPERINTENDE!!T ASSURA!!CE SUPERVISOR l
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SUPERINTENDENT DEPARITE!!T 1
1 DEPART!ENT ENGINEER E!JGINEER OPERATION ANALYSIS INDEPENDENT PROJECT ENGINEERIllG
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l INSPECTION AGENCIES PROJECT ENGINEERING L _ _ _
l MANAGER I
ST.4FF STAFF ASSISTANT ASSISTANT Rev.21 6/6/82 FIGURE 1 4 PROJECTS DEPARTMENT 1-38
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Project Enginnoring during initial design and Station Nuclear Engineering Departannt after plant start-up will review sud evelusto tho ovarall design for safe reliability, inspectability, maintainability and s,
21 constructabili y.
The Division Vice President and General Manager, Nuclear Stations vill be responsible for review of designs for operability, inspectability and maintainability.
Javedination of the design review and evaluation effort by Project Engineering or the Station Nuclear Engineering Department will bs, in part, directed toward the identification and control of design interfaces, radiation and environmental requirements, functions and boundaries, and selection and application of materials, parts, equipment cppurtenances and components.
Project Engineering or the Station Nuclear Engineering Department after plant start-up, with assistance from other organiza-tions, contractors or vendors, shall apply, as applicable, design review and control measures to items such as: reactor physics; loads and loading combination, transient and accident analysis, compatability of materials, structural support, a.ccessibility for in-service inspection, maintenance and repair; and delineatio'n of acceptance criteria for inspections and tests.
Project Engineering or the Station Nuclear Engineering Department after plant start-up, Architect Engineer or Nuclear Steam Supply System Supplier interpret applicable requirements, standards, guides or codes (including classification of ASME Secion Section III items) and use them as a basis for classifying structures, systems and components and establishing boundaries of jurisdiction in each nuclear power plant.
Evidence of design evaluation and reviews and use of alternative calculational methods used to assure verification or checking of design adequacy will be documented and retained by Project Engineering and after plant start-up the Station Nuclear Engineering Department.
Errors and deficiencies discovered shall be documented and appropriate corrective action shall be taken.
The Project Engineering Manager and Station Nuclear Engineering Manager after plant start-up for modifications or their respective agent or designee shall certify that a review has been
(
conducted and the design drawings, stress calculations and Design and l
Construction Specifications and Reports do satisfy design requirements.
Changes to drawings used for construction from the corresponding drawing used for stress analysis shall be certified, by the person or organization responsible for the stress analysis calculations, to have been satisfac-torily reconciled with those calculations.
Copies of the certification shall be attached to the copies of the Design Report, design drawings, stress calculations and Design and Construction Specifications and Reports which are made available, as applicable, to the Inspector for review and certification and the enforcement authorities having jurisdiction over the nuclear power plant installation as provided by ASME Section III of the Codes for Classes 1, 2, 3, CS, MC and CC.
3-2 Rev. 21 6/6/82 i
Commonwealth Edison
3-2 Design Changen Design changes are controlled through document revisions rasulting from design change requests and/or design change notices and are reviewed and evaluated in the same way as the basic design documents.
Site and Station design change requests will be reviewed by the Site Quality Assurance Superintendent or designee, Station Quality Assurance Engineer or Inspector, Technical Staff Supervisor, Project Engineering personnel or Station Nuclear Engineering Department personnel after plant start-up for plant modifications and/or Architect Engineer, es applicable, and will be approved by Product Engineering or the Station Nuclear Engineering Department after plant start-up for plant modifications after which the approved change will be incorporated in design documents, approved, released and distributed.
l The extent of the evaluation will be determined by the complexity of the change and its safety-related function with respect to the original design.
Coordination of review and evaluation of design changes will be by Project Engineering or the Station Nuclear Engineering Department after plant startup for plant modifications.
The control of documents will be maintained within the system described in Quality Requirement 6.0, " Document Control."
Plant modifications will be evaluated in accordance w'ith the requirements of 10CFR50.59 and to the requirements of the ASME Boiler and Pressure Vessel Code Section III and will be submitted to the Director 21 Nuclear Safety / Supervisor Off-Site Review and the Station Superinten-dent.
Also, for Code work the modification will be reviewed with the Authorized Nuclear Inspector who will then stipulate the inspections he intends to make prior to implementation of the modification work.
The Station Superintendent authorizes the modification.
The Technical Staff Supervisor reviews and approves the proposed modification and is respon-sible for verifying that operating procedure changes are accomplished as to station modifications.
The Station Training Supervisor is responsible that required training concerning plant modifications is accomplished for responsible plant personnel where the performance of their duties may be af fected.
Quality Assurance assures such training is completed.
The Supervisor Off-Site Review reviews and approves proposed modifications to plant systems and components involving a revision to the Technical Specifications or a previously unreviewed safety question.
Evaluation and approval of the substitution of equipment is performed by the Technical Staff Supervisor and either the Operating Assistant Superin-tendent or Maintenance Assistant Superintendent.
The Station Nuclear Engineering Department or equipment vendor provide engineering enalysis as required by the design specification 3-3 l
l Rev. 21 6/6/82 Commonwealth Edison
us requisition,end/or lottor will incorporsto, by reforanco, thocs documents such as' specifications, drawings, proposals, supplementary proposals, etc., and any conditions of award which form the basis for the evaluation end award.
Edison Purchasing, based on the recommendation letter, its own evaluation and the purchase requisition, shall conduct necessary negotiations and clarifications and make the award to a bidder on the Approved Bidders' List.
Any changes evolving from the procurement ectivities involving technical or quality assurance matters, either for the original purchase or subsequent change orders, shall be approved by the originator of the purchase or change order requisition.
The Project Engineering Manager or the Station Nuclear Engineering Manager after plant start-up will assign authority for ovaluation of the vendor quality assurance program, prior to final award of the contract or purchase order, to the responsible Project Engineer who will request such evaluation be undertaken by the Director of Quality 21 Assurance (Engineering-Construction).
Quality Assurance evaluates all such vendor quality assurance programs.
The Quality Assurance Coordinator assigned to the Station Nuclear Engineering and Project Engineering Departments is responsible for assuring that the evaluation is carried out and for auditing the manuals of bidders being recommended as acceptable for award as to resolution of comments received by Engineering from Quality Assurance and others plus evaluation by Engineering.
As part of the vendor quality assurance program evaluation, the Quality Assurance Coordinator will assure all vendor quality assurance program deficiencies are resolved.
Concurrence by Quality Assurance shall be required.
If the vendor program deficiencies are minor and/or may be corrected by specific procedures for the work to be done, the resolution may follow an award and shall be a condition of the award.
For procurements performed at certain construction sites by the Purchasing Department satellite organization involving safety and Code-related items, the preparation of the necessary procurement documents is the responsibility of Project Construction.
Procurements by the site Purchasing organization are under the control and management of the General Office Purchasing Department and associated procurement documentation packages are formulated from specifications and drawings issued and approved by Engineering.
The cognizant Field Engineer prepares the suggested list of prospective bidders for each procurement package from the Approved Bidders' List with direction from the site Purchasing Department Buyers.
The final list of prospective bidders and procurement bid package is approved by the Site Construction Superintendent or Project Engineer or their designated alternate.
In cddition, such procurement bid packages involving the purchase 1
l 4-3 Rev. 21 6/6/82 Commonwealth Edison
will bo proyided. Thn proceduras includa spscifications and ccesptanco criteri'a as well as vendor documents. Complex procedures include checklists as part of the procedure and caution notes applicable to specific steps in the procedure are included.
The current revision of the Station Procedures Manual is available in the Station Control Room and is additionally provided to key operating and management personnel.
Maintenance and repairs to structures and equipment after construction and testing is completed are the responsibility of each Maintenance Assistant Superintendent and are performed in accordance with applicable drawings, procedures, instructions, and/or checklists for Code and safety-related work. When ASME Code work is involved, these documents shall be submitted to the Authorized Nuclear Inspector for insertion of his hold points. Drawings procedures, instructions and/or checklists are used for maintenance and repairs outside the scope of normal station craft maintenance capability. When procedures and/or checklists are not available for work outside the scope of normal station maintenance craft cepability, an outline of'the steps to be followed will be prepared to assure proper completion and testing of the maintenance or repair work.
These procedures and/or checklists or outlines are supplemented as necessary by instructions from the personnel responsible for directing the specifi~c maintenance or repair work. Maintenance, modification and inspection procedures and other quality assurance related documents are reviewed by Quality Assurance personnel to assure the need for inspection, identification of inspection personnel, and documentation of inspection results plus necessary inspection requirements, methods and acceptance criteria is provided.
Each Station Superintendent or his designee is also responsible for preparation of procedures to assure the safe operation ahd refueling of the Station in accordance with requirements of the NRC operating license. The Division Vice President and General Manager, Nuclear 21 Stations provides direction for the preparation of necessary instructions and procedures to accomplish the Station activities in a uniform and systematic manner.
l Procedures and instruction supplementing the Quality Procedures
'of the Quality Assurance Manual generally will be prepared, reviewed and approved within the individual departments, Generating Stations and Construction Sites responsible for the activities involved as the need erises and their use monitored by Quality Assurance Administration.
Any CECO departmental group involved with nuclear plant design, procurement, construction or operation may propose procedures as necessary to meet i
regulatory, ASME Code or other applicable code requirements.
l 5-2 Rev. 21 6/6/82 Commonwealth Edison
Control and approval of subcontractors quality assurance programs, procedures and personnel qualification, are the responsibility of the specific contractor involved.
Such contractor actions are to be-documented and will be subject to audit by CECO.
7.2 Evaluation of Vendors An evaluation of vendor capability will be required for ASME Section III and safety-related items.
Where valid records of vendor cepability and quality performance are not available to CECO, a survey of the supplier's facilities, capabilities and quality assurance system will be made by CECO or its designated representative.
For items requiring l
ASME Code conformance, vendors must be able to meet ASME Code requirements.
The Project Engineering and Station Nuclear Engineering Department Quality Assurance Coordinator will be responsible for assuring that vendor or contractor.. Quality Assurance Program evaluations are carried out.
The Purchasing Department will maintain the Approved Bidders' List for contractors and suppliers of ASME and safety-related items.
Addition of vendors to the Approved Bidders' List shall only be made upon approval by Station Nuclear Engineering Manager and the Manager of Quality Assurance, or their designees, as to meeting technical and quality assurance requirements.
For vendors or contractors to be placed l
on the Company Approved Bidders' List on the basis of having an approved 21 Quality Assurance Program for ASME or safety-related items or work, a controlled copy of their approved Quality Assurance Program shall be assigned to the CECO Manager of Quality Assurance.
Section 9.0 of this report, " Control of Special Pro. cesses,"
establishes the evaluation and assessment of certain process and inspection capabilities of the vendor such as welding, heat treatment, and nondestructive examination.
Past performance of a contractor / vendor will be considered during procurement activities by CECO.
Prior to contract or purchase order. award, the bidder's capability and quality performance will be reviewed relative to the product, process, or service being procured.
If records are inadequate, a survey of the bidder's facilities prior to award may be required.
Surveys will include, as applicable, review of facilities, organization, quality assurance program and experience, existing controls, knowledge of special processes, possession of a current ASME Certificate of Authorization, and an understanding of, and a willingness to meet contractor or purchase order requirements.
7.3 Surveillance of Vendor Operations Source surveillance will be carried out through notification points established as a condition of procurement of safety-related or ASME Section III items.
Special consideration will be given for surveillance during manufacture when one of the following is involved:
7-2 Rev. 21 6/6/82 Commonwealth Edison
i-Rojectsd itens shall ba idsntified by tagging and immedictoly l
removed from construction or installation areas (unless physical size -
prohibits this) and segregated in a controlled area to prevent its uncontrolled use or installation.
~
Commonwealth Edison Company will make a technical evaluation of
?ertinent data relating to the nonconformity, including the cause, where inown, and corrective action either taken or planned to prevent recurrence. Also, items which are found to contain defects which could create a substantial safety hazard will be reported in accordance with the provisions of 10CFR Part 21 and as provided in implementing procedures.
Construction deficiencies involving material or equipment are documented and reported to the Nuclear Regulatory Commission and to Commonwealth executive management.
The Site Construction Superintendent or Project Engineer is responsible for this reporting.
The Station Superintendent is responsible for investigating and reporting operating occurrences.
An Investigative Report is prepared for i
occurrences or departures from the safety limits prescribed in the Station Technical Specifications.
Occurrences and departures from the safety limits are documented and reported to the NRC as required by the Technical Specifications.
The Station Superintendent appoints personnel to investigate the occurrence and issue an Investigative Report in accordance with the Technical Specifications and a Quality Procedure.
This report is distributed to the Divison Vice President and General Manager - Nuclear Stations and Station Superintendents.
Reports of occurrences that result 21 in significant damage or have significant safety imp)lications are reviewed with the Vice President (Nuclear Operations and then forwarded to the executive management.
The appointed personnel are responsible for determining the cause of the occurrence, developing recommendations intended to preclude recurrence and issuing a report which shall include: a detailed i
description of the occurrence, the findings and recommended measures for corrective action.
When deviation from accepted normal operation of a reactor and its associated equipment occurs, or when a reactor scram occurs (other than these associated with a reportable occurrence), the Station Technical Staff investigates the deviation and issues a Deviation Report r
covering the nature of the deviation (e.g., process difficulty, equipment inadequacy, procedure inadequacy), its cause, the hazard or potential hazard to operations and recommendations for corrective action.
15-2 Rev. 21 6/6/82 Commonwealth Edison
The report documents the deviation and providas o record frcm which to establish a trend in the operation. Such reports are distributed to the Division Vice President and General Manager, Nuclear Stations, the Operating Assistant Superintendent, Technical Staff Supervisor and Manager of Quality Assurance.
The Maintenance and Master Instrument Mdchanic receive a copy of the deviation report if maintenance or instrumentation work is involved in the correction of the deviation.
Reports involving significant reactor safety considerations are reviewed with the Division Vice President and General Manager - Nuclear 21 Stations and then forwarded to other executive management.
Such deviations will be reported to the Nuclear Regulatory Commission as required by the Technical Specifications.
During construction the Project Engineering Project Engineer and during plant modification, the Station Nuclear Engineering Department Project Engineer have responsibility for resolution of nonconformances and such resolution will be approved by the Site Quality Assurance Superintendent or designee at the construction site or by a Station Quelity Assurance Engineer or Inspector at the operating station.
Nonconformance to system operation and technical specification requirements will be resolved through actions by the Operating. Assistant Superintendent with the approval of the Station Superintendent.
I l
15-3 Rev. 21 6/6/82 Commonwealth Edison
For correctiva cction nonconformances, the Edison Site Quality Assurance Superintendent or c asignee will establish and maintain a Nonconformance Report (NCR) Station Log to monitor the prompt resolution and closing of c11 NCR's plus maintain a file of all NRC's or equivalent documents that cra submitted by the site for CECO resolution and approval.
The cumulative monthly deviation report, which indicates the NCR number, deviation description and resolution, such as' reject, replace, use-as-is or repair, approval status, date of resolution and whether corrective action is completed, is distributed to involved corporate and line management for information, review and possible action.
The responsible manager brings significant nonconformances to the attention of corporate management for action where satisfactory resolution cannot ba achieved by Engineering with a contractor.
For Operations, corrective action identified from nonconformances, incidents and deviations, trend studies and audits are varified for satisfactory. completion to preclude repetition.
When corrective action is required to correct nonconformance to Code requirements, such corrective action shall be made available to the Authorized Nuclear Inspector.
Any revision to Travelers involved with corrective ' action related to nonconformance for station modifications shall be reviewed with the Authorized Nuclear Inspector for his review cnd insertion of hold points.
This system will provide follow-up to assure that corrective measures are effectively implemented.
Also, significant conditions are reported by the responsible manager and nonconforming items are routinely reported by the responsible engineering organization to appropriate levels of management.
The Technical Staff Supervisor verifies completion of corrective actions for maintenance, repair, refueling and operation activities.
The Station Quality Assurance Engineer or Inspector for maintenance and operating issue reports indicating the status of corrective action in progress.
These reports are routed to the Division Vice President and 21 General Manager, Nuclear Stations and the Manager of Quality Assurance and reviewed to assure prompt implementation of the corrective action.
Site contractors and off-site vendors will be required to follow-up on corrective action commitments within their quality program.
The Site Quality Assurance Superintendent or designee will be responsible l
I for surveillance of site corrective action.
The Project Engineering Project Engineer is responsible for assuring that review and evaluation of nonconformance reports are carried out to determine the need of l
corrective action.
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disruption of orgentzstion: bning audited. An cudit plcn will b3 maintained in order to schedule audits of site contractors. Audits of off-site contractors generally will be conducted in conjunction with plant visits for witnessing inspection points by a qualified auditor.
Also, periodically Quality Assurance will participate in such audits or perform independent audits to assure effectiveness of the program, compliance to the program and fulfillment of procurement requirements.
The elements in the quality program, in procurement documents end in related codes and standards, are subject to systems audits. Also, items received, fabricated and constructed or installed for use by Commonwealth Edison Company in its nuclear power plants are subject to audits.
Audits will be performed selectively at various stages of contracts on a varying frequency, based on the nature and safety significance of the work being done to verify compliance and determine the effectiveness of procedures, inspections, tests, process controls and documentation. For Code materials, when e Material Manufacturer or Meterial Supplier, as applicable, does not hold a Quality System Certificate (Materials), the CECO audit frequency shall be at least once cnnually during the interval in which Ceco purchased material is being controlled by the Material Manufacturer or Material Supplier. In addition to these audits, Quality Assurance will conduct approximately annually, overall system audits of the NSSS vendor, the Architect Engineer, site contractors, and involved Edison Departments.
Audits of CECO are also performed by the Authorized Inspection Agency as required by the ANSI N626 series of Standards.
For operating stations, periodic Quality Assurance Department audits will be performed to verify compliance with, and the sffectiveness of the program. Audits covering operating will be performed in accordance with the Technical Specifications under the direction and responsibility of the Director of Quality Assurance (Operating) independent of the Production Department. Surveillance, in-service inspection and Stores activities will be performed under the direction and responsibility of the Quality Assurance Supervisor (Maintenance).
Audit results and recommendations of corrective action will be documented and reviewed with I
the management of the Station.
Verification of the completion of l
corrective action recommended in audit reports will be performed by the Technical Staff Supervisor or Quality Control Supervisor. Follow-up of 21 open stat'.on items is tracked by the Action Item Record's (AIR) System.
Where an audit item is placed under the AIR system for tracking completion approval as to satisfactory completion of corrective action shall be obtained from the responsible station Quality Assurance Engineer or Inspector.
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Audits will be conducted by qualified personnel who are familiar with written procedures, standards and processes applicable to the area being audited, but who do not have direct responsibilities in the areas being. audited.
A report shall be written for each audit. An audit report package consisting of Summary Sheet, Attachment Sheet, Checklists or Agenda and any additional pertinent details recorded on additional sheets necessary to' support a finding (s) will be on file. The audit report shall be sent, as applicable, to the Executive Vice Presidents, Vice President (Engineering), Vice President (Nuclear Operations), Manager of Station Construction, Manager of Projects, the Station Nuclear Engineering Manager, Manager of Quality Assurance and the Directors of Quality Assurance and Division Vice President and General Manager - Nuclear 21 Stations Nuclear Stations for management review and action. The above sected system audits are also sent to the Vice Chairman for review and evaluation and action as deemed necessary by the Manager cf Quality Assurance. Also, monthly to bi-monthly periodic reports on quality assurance activities are submitted to top management. Such reports, in part, provide bases for periodic top management reviews and discussions of quality assurance activities, implementation status and effectiveness.
Such reviews and discussions are held by the Vice Chairman with the Manager of Quality Assurance and with other executives.
Audits shall be scheduled and follow-up review of deficient areas or adverse conditions and follow-up on corrective action commitments shall be performed by Quality Assurance to assure effective implementation has been carried out.
Deficiencies in the execution or implementation of. corrective action will be brought to the attention of the person who is responsible in the area involved. Continued deficiencies, or failure to implement corrective action will be reported in writing by Quality Assurance to appropriate executives within Commonwealth Edison Company.
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