ML20078L394

Proposed Change to QA Program Description

ML20078L394
Person / Time
Site:	Limerick
Issue date:	11/21/1994
From:	PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:
Shared Package
ML20078L389	List: ML20078L386 ML20078L394
References
NUDOCS 9411290196
Download: ML20078L394 (16)

Text

{{#Wiki_filter:i j \\ ATTACHMENT 1 Limerick Generating Station Units 1 and 2 Proposed Change to the Quality Assurance Program Description 15 Pages 9411290196 941121 PDR ADOCK 05000352 P PDR

-Ef S i N - 10 OO L p.' ? 8-LGS UFSAR f. '$'ignificant operating abnormalities or deviations from normal and expected performance of unit equipment and the ~ plant staff that affect nuclear safety. This shall g normally be accomplished by review of _PORC meeting minutes, special reports, or reports of audits. g. All Reportable Events. h. All recognized indications of an unanticipated deficiency in some aspect of design or operation of structures, systems or components that could affect nuclear safety. This shall normally be accomplished by review of PORC meeting minutes, special reports, or report's of audits. i. Reports and meeting minutes of the PORC. -j. Preventive and corrective maintenance program, k. Assessment of the effectiveness of the Quality Assurance Program in terms of the scope 'o f the program and processes used. 1. Assessment of the effectiveness of the line safety assessment function (PORC) in terms of its scope of review and processes used. The NRB will utilize, as necessary, the Operating Experience Assessment Program (OEAP) of the Licensing Section, and the Nuclear Quality Assurance Department to review current plant and industry concerns and perform special studies and investigations. The NRB Chairman will report directly to the Senior Vice President and Chief Nuclear Officer on a regular basis concerning 'th'e requirements for assuring the public and plant personnel of safe operation of the nuclear power plants. A written summary of NRB activities is sent to the Office of the President and Chief Operating Officer of the company. l Minutes of NRB meetings and reports of actions taken shall be prepared and retained and shall identify documents reviewed, decisions and recommendations made, and actions taken by the NRB. The minutes shall be promptly (normally within 14 days following each meeting) forwarded to the Senior Vice President and Chief Nuclear Officer followed by copies to other members of management as appropriate. 13.4.4 AUDIT PROGRAM Audits of plant activities in the following areas shall be performed under the cognizance of the NRB: The conformance of unit operation to provisions contained a. within the Technical Specifications nd applicable License Conditions at least once every -14 onths. sL'l 13.4-6 . a 1. 0" 11/9'

. _[O" LN !OS $ 1 j. fG v LGS UFuAR 1 4 ~ b. 'The performance, training and qual fications of the operating staff at least once every months. A c. The results of actions taken to rect deficiencies f occurring in unit equipment, structures, systems or method of o eration that affect nuclear safety at least l once every s+x months. l dl4 d. The perform e of activities required by the operational quality assurance program to meet the criteria of 10CFR50, Appendix B, at least once every 24. months. The Emergency Plan and implementing procedures at least e. once every 12 months. f. The Security Plan and implementing procedures at least once every 12 months. The Fire Protection Program and implementing procedures g. at least once every 24 months. h. An independent fire protection and loss prevention inspection and audit shall be performed at least once per 12 months utilizing either. qualified offsite PECO Energy personnel or an outside fire protection firm. i. An inspection and audit of the fire protection end loss prevention program shall be performed by an outside qualified fire consultant at intervals no greater than 36 I months. The radiological environmental monitoring program and'thh'e j. results thereof at least once per R months. M k. The Offsite Dose Calculation Man al and implementing l procedures at least once per 24 months. 1. The Process Control Program and implementing procedures l at least once per 24 months. Any other area of unit operation considered appropriate l m. by the NRB or the Senior Vice President and Chief Nuclear Officer. f n. The performance of activities required i,2 the Quality Assurance Program to meet the criteria of egulatory Guide 4.15, December,1977, at least once per months. i 13.4-7 --R c'? O" 11/04 j l l l

M L8$~lOgDC p z( 8 - LGS UFSAR j l Audits shail includa verification of compliance and effectiveness of linplem~entation of programs, procedures, regulations, and license . provisions in the areas audited. Written reports of such audits shall be transmitted for appropriate action to the Senior Vice President-and Chief Nuclear Officer and management having t responsibility in the areas audited within 30 days af ter completion of the audit by the auditing organization. i Audits shall be performed by the Nuclear Quality Assurance Department or by specially selected groups or individuals who have ' no immediate responsibility for the activity they audit and do not, while performing the audit, report to a management representative who has immediate responsibility for the activity being audited. i Timely follow-up action, including re-audit where appropriate, shall be taken when deficiencies are noted. The audit program and schedules shall be reviewed semi-annually by the NRB to ensure that the audits are being performed in accordance with the Technical Specifications. The audit program is described in Chapter 17. TECMICAL REVIEW PROGRAM 13.4.5 INDEPENDENT S.'.?ETY ENOINEERIliG GROuF An ndependent Safety Engineering Group was established prior o initia fuel load of Unit 1 to perform independent reviews of ant The ISEG examines unit operating characterist' s, NRC operati s. issuances, 'ndustry advisories, Licensee Event Reports, nd other sources of it design and operating experience fcrmation, including unito of similar d2 sign, which may ind' te areas for improving unit sa ty. The LGS ISEG is compoe d of at least fiv dedicated, full-time engineers / scientists, in uding the Super

• tendent - ISEG, located on-site.

Each ISEG member s a bache r's degree in engineering or related science and a minim of years of professional level experience in their respective f ds. The LGS ISEG Manager has a ninimum of six years of experi-ce ' the nuclear field. The LGS ISEG reports to the Director Nuclea Quality Assurance. The ISEG is responsib for maintainin surveillance of unit activities to prov' e independent veri ation that these i activities are pe ormed correctly and that uman errors are reduced as much s practical. The ISEG is not sponsible for sign-off func 'ons. The ISEG is responsible for performing independent reviews plant operat' ns, reviewing operating experiences which may indica the nee for improvements, recommending needed improvements, d a V1 sing management on the overall quality and safety o perations. i Ocl A bAeYl Ek 'n 'I*'"^ b" P H 4 - 6, 13. 4-9 l 13.4-8 E c'z 0' 11/9' h

C C i' L-.i'i-10UOY -f, a-o I C LGS UFSAR Th LGS ISEG makes detailed recommendations for revised procedu s, equi ent modifications, maintenance activities, oper tions ~ activit' s or other means of improving unit safety. Such j recommend -ions are submitted directly to the affected organization \\ with copies to the Director - Nu ear Quality Assurance and e Senior Vice President - Nuclear The LGS ISEG perfo s the functions of a independent safety engineering group as d cribed in Item I.B . 2 of NUREG-0737. The average years of nuclear-lated experie e exceed the 1 to 2 years of nuclear-related experien stated

• section 13.4 of the SRP.

When members of the LGS ISEG are , laced, the replacements have a minimum of 2 years' experie e i their field and 1 year of nuclear-related experience. Also, because the LGS nd PBAPS designs ar similar, many of the PBAPS ISEG's assese.ents, particu]3rly in t areas of design, training, correc e maintenance and, to some ex nt, operations, may be directl applicable to LGS and vice-versa, e PBAPS ISEG is similar y' composition to and has similar respons ilities as the LGS I EG. \\ The nager - ISEG reports to the Senior Vice President - Nu. ar th ugh the Director - Nuclear Quality Assurance on matters of bou routine and a safety-related nature. l l 13.4-9 E c.v. ; No../C;

-EG L % - jo 6C: 4 3 af 9 - ATTACUMEF 1 - P t 13.4.5 INDEPENDENT TECHNICAL REVIEW PROGRAM An independent Technical Review Program shall be established to satisfy the following: 13.4.5.1 The Independent Technical Review Program responsibilities shall encompass: a. NRC issuances, industry advisories, Licensee Event Reports, and j other sources that may indicate areas for improving plant safety; b. Internal and external operating experience information that may indicate areas for improving plant safety; c. Plant operating characteristics, plant operations, modifications, maintenance, and surveillance to verify independently that these activities are performed safely and correctly and that human errors are reduced as much as practical; and i d. -Making detailed recommendations to senior management of the affected organizations, with copies to the Director'-Nuclear Quality Assurance and the Senior Vice President and Chief Nuclear Officer for revising procedures, equipment modifications or other means of improving riuclear safety and plant reliability i 13.4.5.2 The Independent Technical Review Program shall utilize several on-site i personnel who are independent of the plant management chain to perform i the reviews. These individuals shall report to the LGS Site Quality Division Manager. The LGS Site Quality Division Manager is responsible to ensure l the Independent Technical Review Program is implemented as indicated in section 13.4.5.1. The Site Quality Division Manager shall utilize information obtained as part of this program as input to advise management on the i overall quality and safety of operations. I 13.4.5.3 The written record of technical reviews shall be reported to, at a minimum, l the Senior Vice President and Chief Nuclear Officer, the LGS Station Vice President, the Nuclear Review Board, and the Director-Nuclear Quality Assurance. Records of the activities of the Independent Technical Review i Program shall be prepared and forwarded each calendar month to the Director-Nuclear Quality Assurance. 13.4.5.4 Personnel performing reviews pursuant to section 13.4.5.1 shall have at least 3 years of related experience and a bachelor's degree in engineering l or a related field; or shall have at least 8 years of related experience. The LGS Quality Division Manager shall meet the requirements of ANSI /ANS-3.1-1978.

g. is.4 6, i 3.4.4 l

~ G e k T-4 W ID f f LGS UFSAR S. Apprise the Senior Vice President and Chief Nuclear Officer; the Vice President, Station Support; the Vice President, Limerick Generating Station; and the Nuclear y.., Review Board periodically of the status of the Quality Assurance aspects of Limerick Generation Station's operations, and immediately of significant problems affecting quality. i. Control contents and revisions of the Quality Assurance l Program Description. j. Ensure that personnel involved in implementing the NQA procedures are trained and/or qualified, as appropriate. k. Contract for QA/QV consulting services as necessary. 1. Provide support for QA/QV training and qualification programs, as required, for implementation and execution of the NQA Program. Establish and maintain the Evaluated Vendors List (EVL) m. of evaluated and qualified vendors in accordance with administrative procedures. Perform assessment / surveillance of vendor activities as l n. appropriate. Establish, administer, and coordinate the Nuclear Quality o. Assurance Program associated with modifications, and capital equipment installation or renewal. p.

Assess, through NQA Assessments, Surveillances, 'and l

Quality Verifications, the adequacy and effectiveness of activities covered by the NQA program. 17.2.1.2.3.1 Limerick Quality Division The Limerick Quality Division is under the supervision of a Manager who reports to the Director, Nuclear Quality Assurance. The Division is composed of three sections: Assessment, Quality Verification, and Quality Support. The Manager, who meets the requirements of ANSI /ANS-3.1-1978, is responsible for: a. Providing technical and administrative direction to the Division, b. Providing single point accountability for all site quality activities. O [ HFOkjm1pfl o gV O N L vf NO CHAtME.! h N'S PAoc l l 17.2-7 P c 1. M../0; l

-EC" L74' !0807 LGS UFSAR . ci. . Reviewing .and approving site-generated- -l administrative procedures. and rndependen+' l l. d. Formulating the site Assessment Programs. Technic.Al fdvidu) e. Conducting assessments, surveillances, and . [- verifications. f. Identifying specific and programmatic i deficiencies, and tracking these items until they are fully resolved, in accordance with Administrative Procedures. Performing trend analysis. l g. h. Providing periodic reports to the Director, NQA, on the status and adequacy of the nuclear facility Quality Assurance Program and i advising of any problems requiring special attention. i. Approving Stop Work directives. j. Providing and maintaining a qualified and suitably trained quality assurance staff to carry out required project and staff functions. 17.2.1.2.3.1.1 Assessment Section The Assessment Section is und>ar the supervision of the site Quality Division Manager. The Manager has the following responsibilities: Provide administrative supervision of the activities of a. the section. b. Direct the scheduling,

planning, and performance of l

assessments and surveillances in accordance with written procedures to ensure compliance with the NQA Program and Technical Specifications. oversee the preparation of NQA assessment checkli,sts. c. d. Review and approve results of assessments and surveillances. l e. Ensure that items requiring corrective action are properly identified and documented in accordance with NQA procedures. i nmf./t4 17.2-8 - P c'f -a

h L.9[-lOgDg-- 4' *i J. A ~ LGS UFSAR .i i 17.2.1 me Independent Safety Engineer The Limerick Indepen ngine.* oup (ISEG) composition les are described in Section 1 and e 1 17.2.1.2.3.3 -Corporate Nuclear Quality Division The Corporate Nuclear. Quality Division is under the supervision of a Manager who reports to the Director, Nuclear Quality. Assurance. The Division consists of two sectica s: Assessment, and. Administration. l The Manager, Corporate Nuclenr Quality, is responsible for all Corporate Nuclear Quality Division activities. This includes: a. Manuals and procedures. l b. Vendor assessments and surveillances. c. Training. d. Oversight of the quality activities of the Station Support Department. Identification of specific and programmatic deficiencies l e. and tracking of these items until they are fully resolved. ~ l f. Performing trend analysis. Conducting internal assessments at the corporate offices. ~ 'l g. 17.2-12 .Rev. !!cy _ / 9 ; l

-Get g;-l-l-9&DS~' LGS UFSAR 17.2.2312, Information concerning plant conditions and status will be made available to NQA personnel to enable responsible NQA supervision to determine when assessments, surveillances, or verifications should be performed. This information may be in the form of communications with plant management or staff personnel through daily or periodic meetings. In addition, NQA personnel shall periodically review operating logs, maintenance work schedules, fuel handling operations schedule, ISI/IST inspection program, and modification proposals, to ensure that NQA personnel are involved in day-to-day activities that are important to the safe operation of LGS. 17.2.2.13 Personnel performing or verifying quality-related activities shall be: a. Trained in the purpose,

scope, and implementation of quality-related manuals, instructions, and procedures.

b. Trained and certified in the principles, techniques, and requirements of the performed activity and such certification shall delineate the specific area of expertise and criteria used. 17.2.2.14 The training / certification program shall include documentation of the obj ective, content, enrolled attendees, date of attendance, and examinations given. 17.2.2.15 The training / certification program shall provide for retraining, re-examination, an. or recertification as appropriate. Quali y buVtrion knager u recpon.s De. % en.soce. +1,e. ,,,,,2,,s rndependen t-Techical Renew Proyam re.vn ews l The +fena<fer, Indepe ent Sc c-y Enginccring mrcup tI_,, as rcspcasible for revic.fing-plant operating characteristics, NRC issuances, and other appropriate resources of plant design and operating experience information that may indicate areas for improving plant

safety, and for input and closure of 1020 recommendations in the PIMS database #

+hd r'eaulk from li1ese. reNiews. Th. rnh.oende.nf hhnneal Reveo Prot.a n is desenhet in Jee+non \\

13. V..r.

17.2-26 .ns. -; " ~f. / - l

-{C! LAN - l C-$6 -; . il r g LGS UFSAR hateandresults. ~ c. d. Information related to conditions adverse to quality. i Inspector or date. recorder identification. e. f. Evidence as to the acceptability of the results, j 17.2.17.9 y NQA and other organizations responsible for record control are defined in the Administrative and Implementing Procedures. l 17.2.18 AUDITS 17.2.18.1' l Compliance with the requirements and guidance for establishing and implementing the Quality Assurance Program is assured through the NQA l vendors. assessment program for PECO Energy Company nuclear organizations and ~ j i' -17.2.18.2 The NQA assessment program shall consist of: f a. Assessments - Documented activities performed in accordance a with ANSI N45.2.12 as described in Appendix 17.2.II. Documented activities identical to l b. Surveillances Assessments except that no formal. assessment plan and assessment checklist are generated and no exit interview is conducted if no noncompliances are identified. Surveillances are normally initiated on short notice based on plant conditions and may include observation of work in process. l 17.2.18.3 The aspects covered by the assessment program include designing, purchasing, fabricating,

handling, shipping,

storing, cleaning, erecting, installing, inspecting, testing, modifying, and maintaining LGS Q-Listed structures,

systems, and components.

In addition, assessments may be performed on non-Q activities that will enhance operational safety as determined by appropriate management. Any procedures, instructions, drawings, procurement documents (for l vendors), activities, work-in-progress, processes, hardware documents, or records that are related to the items above are subject to objective assessment evaluation for compliance with the PECO Energy Company QA P ram. For ) ~ L)O C)#y A N AW 17.2-62 Rev. 4 Nov./94 t

-6C..C L Tl -Mege Y o LGS UFSAR 17.2.,1.8.4 NQA is responsible for the planning, performance, reporting, and follow-up of the assessment program to determine compliance with the l clements and effectiveness of the NQA Program. 17.2.18.5 Assessments and Surveillances shall be performed in accordance with written procedures by NQA personnel, who are independent of any ' direct responsibilities for the performance of activities which they will assess. NQA may request the assistance of personnel from other l disciplines or technical specialists who are independent of areas being assessed. The Director, NQA, shall establish the assessment program personnel l qualifications and the requirements for the use of technical specialists to accomplish the assessment of the Quality Assurance I Program. Personnel shall be selected f c. r quality assurance assessment assignments based on experience or training which l establish that their qualifications are comme.nsurate with the complexity or special nature of the activities to be assessed. In j selecting personnel for assessment assignments, consideration shall be given to special abilities, specialized technical training, prior pertinent experience, personal characteristics, and education. 17.2.18.6 Assessments shall be regularly. scheduled on the basis of the status l ~ and safety importance of the activities. The following activities of the Quality Assurance Program shall be assessed at least every 2 l years, except as otherwise indicatedVin sechon G.V.'/, j Training -fun,i4-steff is asscaso -unlly)- a. I b. Health Physics c. Che 'stry d. Fuel /In-ssel aterial c. Shift Op atio q f s f. Su eillance Testing g. Maintenance of Ir.struments A A a 17.2-63

mev, nev _ f e 4-

Ge&t 74-1050t r,0uEWS-- ^ LGS UFSAR s h '. ISI/IST i. Maintenance /I&C j. curement k. Modi ' cations i 1. Radioact1 e Wast aterial m. Plans - Incl es: Fire P otectio-Plan Eme ency Plan ssessed annually) P sical Security lan (assessed annually) a o o i al Enviro ental Monitoring Program -fasscaccc annual.y, Nuclear Engineering } Other areas that shall be subject to scheduled assessments include preparation,

review, approval, and control of specifications, procurement documents, instructions, procedures, and drawings; receiving and installation inspections; and vendor activities.

Regularly scheduled assessments may be supplemented by unannounced or unscheduled assessments or surveillances as determined by NQA. r. Ji-W 17.2.18.7 Assessment and surveillance procedures shall require that nonconformances which are identified be documented in suffic'ient detail to assure that required corrective action can be effectively I carried out by the assessed organization. Corrective action may be recommended, as appropriate, by NQA. 17.2.18.8 Responsible management shall take the necessary action to correct any identified deficiencies and to report the cause of the deficiency and the corrective action to NQA. Unless justified in writing as not appropriate, corrective action intended to prevent recurrence shall also be taken and reported. 17.2.18.9 When corrective action measures are indicated, follow-ups or re-assessments of applicable areas shall be conducted, to assure l implementation and effectiveness of corrective actions. , y. 17.2-64 -nc f, Mcy,fg

WL.'14 - t OW LGS UFSAR 17.2.18.10 The'results of the assessment' program shall be documented by NQA and l p/ distributed to the. appropriate - levels of management including the l management of the assessed area. Assessment results shall be analyzed and a statement regarding the l effectiveness of the QA Program in the areas assessed shall be ' included in the Assessment Report. l '17.2.18.11 Assessments performed under the cognizance of.the N"uclear Review l Board are discussed in Section 13.4. 17.2.18.12 The assessment program shall be periodically reviewed and revised as l necessary to assure that coverage and schedule reflect current activities. 17.2.18.13 The Director, NQA, is responsible to identify overdue corrective action to the appropriate responsible management. 34 O l b F~or L4rms ont7 Lbelumy kt*w k try \\ 17.2-65 Rev. 4 Nov./94 l . [

l ll A * > 44 oq E O i N tt CY O r O O NN P I A t E AP e T R RM A T UO S S I t C nS Y aSC S G L 2 uAI A t N C i N T I D A Y C 4 T n AN oTE Y T I L RA irLE E1 E A A A F N SUI A E S w H S T aQ P O I L o L 4 T Y N N N N NA RRE T T K N oAD 2 T T E O E E UI I N D D S D C E A EL EN N f TN N EN N l F A L I A R MO E RO E ECO T E LI J AU* E n D ROO G ST T TT T ! T T SC N SC N DvC N CH E E I E E O S A I I NR P R I P R EE R ! S I NE R E R T U AM N S A U SS E M E S E M R A S CC U A U U I D N o OED M A P D P P P l L U S S S L U F N N T O T T N I N N T T E A E E M N D I N C D T D R C EN N F N YR N N R O E ILPT l OIO E 1YN MO E T O T E R T 0TO E C 0U G ST T T T f A I V C N APC IN S A SC N i UUE R E ) UM N EE R YS R OSS E SS A S E T E E R COD M A P U P P A U A U U D EP S U S S O t s K b& h gg, G R R k3 Sb g' e E ES \\ G I g AN S / p [g xk A G ^ t L l M / ke h } / 7 / A q 2 S D $e gY N T O T T I N T N N T E A E E N D C D T D I E I N YRN t I Et N FN N P R KYJ Mo E RO E EA l VC T UOIO E T CTO G ST T ET PT T N APC N RUS A SC N I OSS l UUE R MUM N EE n Y S E R I A SS S E T E E I QD M A P U P P L U A U U S U S S O { f

eW-L'?'! - !000? o. ~ M6 LGS UFSAR 2. ANSI N45.2.4, Section 3, Preconstruction Verification - Subsection (3) requires the checking of records of ~ protective measures maintained during storage for conformance to storage requirements. ANSI N45.2.2-

1978, Section 6.4, Control of Items in Storace, requires inspection and examination during the storage l

period. The responsibility within PECO Energy Company for these inspections rests with Materials Management. Compliance with these requirements for checking of records is assured through the auditing and quality verification programs conducted NQA Department personnel along with the monitoring of Materials Management activities by Materials Management supervision. 3. ANSI N45.2.4, Section 7, Data Analysis and Evaluation - A program for processing, reviewing, and analyzing electrical equipment and instrumentation inspection and test data for acceptability is provided in the administrative procedures which govern the repair, maintenance, and testing of electrical equipment and instrumentation. Maintenance is controlled through the use of a work request form that has provisions for cognizant personnel sign-off after completion of the work. Functional testing and calibration procedures, include provisions for review, analysis of data, and approval by signature of cognizant personnel. u.n.: 4. ANSI N45.2.4, Section 6.2.1, Eauinment Tests Installed items requiring calibration are controlled through the preventive maintenance computer tracking system. Tags or labels are not affixed to the item,to indicate calibration status. Reaulatory Guide 1.33, Revision 2, February 1978, " Quality c. Assurance Program Requirements (Operations). " Endorses ANSI N18.7-1976/ANS 3.2. PECO Energy Company shall comply with Regulatory Guide I 1.33, Revision 2, February 1978 and ANSI N18.7-1976/ANS 3.2 during the operational phase except for the following clarifications or alternatives: 1. Regulatory Guide 1.33, Section C.4 and ANSI N18.7-1976/ANS 3.2, Section 4.5, Audit Procram - The I assessment program carried out by the Nuclear Quality Assurance Department shall be performed in such a manner that individual activities in Section 17.2.18.6 are investigated within a period of two (2) years. This investigation shall consist of either assessments I or surveillances. See Section 17.2.18. ~ [0Y m{tvmN 0hly po d e k fM Acg 17.2.II-2 Rev. 4 Nov./94 I I}}