ML20082K721
| ML20082K721 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 08/26/1991 |
| From: | Creel G BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9108300190 | |
| Download: ML20082K721 (8) | |
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D ALTIMORE GAS AND ELECTRIC CHARLES CENTER
- P.O. BOX 1475
- BALTIMORE, MARYLAND 21203 1475 GEORGE C CREEL vietpass w a Nvettan Cunov ooo tec...cs August 26,1991 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:
Document Control Desk
SUBJECT:
Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2: Docket Nos. 50-317 & 50-318 Proposed Chance to Ouality Assurance Procram Gentlemen:
In accordance with 10 CFR 50.54(a)(3), Baltimore Gas and Electric (BG&E) Company hereby requests approval of a proposed change to the Quality Assurance Program for Calvert Cliffs Units 1 and 2. The proposed change would transfer responsibility for receipt i. ection activities from the Nuclear Quality Assurance Department (NOAD) to the recently created Procurement Services Master Unit (PShfU), within the Nuclear Support Senices Department (NSSD). We propose to change the program as shown on the attached markup (see pp. 6,10,20,25,26, and 27). Nuclear Regulatory Commission (NRC) approval is required prior to implementation of this change since the change is deemed to constitute a reduction in the Quality Assurance Program commitments as previously accepted in that receipt inspection personnel will not report directly to the hianager-NQAD. The Quality Assurance Program is also described in Section 1.B of the Calvert Cliffs Updated Final Safety Analysis Report "JFSAR). The UFSAR is updated annually in accordance with 10 CFR 50.71.
Presently, receipt inspection and special testing is performed by the Receipt Inspection Unit in NOAD. This change would consolidate receipt inspection activities by transferring the Receipt Inspection Unit in its entirety (including all present personnel) to PSh1U.
The primary objective of this change is to climinate unnecessary organizational complexity in procurement activities. This change will provide improved accountability and communications within the site procurement organization and will improve overall procurement process quality and efficiency by consolidating responsibility for the process under the process owner.
Plant operation in accordance with the proposed change would continue to satisfy 10 CFR Part 50, Appendix B, Criterion 7 " Control of Purchased hiaterial, Equipment, and Senices". Receipt inspection activities will continue to be performed by appropriately qualified individuals under the BG&E Quality Assurance Program. In addition, measures such as independent quality assurance audits would remain in place to ensure that receipt inspection activities are conducted in accordance with Quality Assurance Program requirements.
9108300190 910826 PDR ADOCK 05000317 P
PDR y
QQO
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Document Control Desk August 26,1991 '
Page 2 Consideiing the above information, we conclude that the proposed change to our Quality Assurance Program will improve the effectiveness of our procurement process. Should you have any questions regarding this matter, we will be pleased to discuss them with you.
Very truly yours,
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GCC/Lh1D/Imd/bjd
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Attachment cc:
D. A. Brune, Esquire J. E. Silberg, Esquire R. A.Capra NRC D. G. hicDonald, Jr., NRC T T. Afartin,NRC L E. Nicholson, NRC R. I hiclean, DNR J. II. Walter, PSC I
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QUALITY ASSURANCE POLICY Revision 27 Quality assurance matters that cannot be resolved by the Managers or Vice Presidents are brought to the attention of the Vice Chairman or the Chairman of the Board for resolution.
Vice President-Nuclear Enercv Division The Vice President Nuclear Energy Dhision, is responsible for ensuring that the QA Program is developed and implemented. The authority to develop QA Program Documents is assigned to designated Nuclear Program Managers. The Vice President. Nuclear Energy Division, is also responsible for ensuring that the requirements of the QA Program that relate to the design, opera-tion, and maintenance of the plant are implemented. This responsibility is carried out through Nuclear Program Managers.
Manacer. Nuclear Ouality Assurance Department The Manager NOAD, is responsib!c for assuring an appropriate QA Program is established and effectively executed for CCNPP. He is responsible for auditing, quality verification, and the vendor evaluation functions for CCNPP. These responsibilities include:
1.
Developing, and revising the QA Policy, 2.
Ensuring that QA Compliance reviews are completed for program acceptability of Control Programs (QAPs and Directives) anc' their revisions before they are approved.
(9) 3.
Taking necessary corrective action, which can include the stoppage of work when manufacturing, maintenance, or modification aethities fail to comply with approved specifications, plans, or - procedures. Such corrective action is arranged through appropriate channels and is delegated when necessary. When a unit is operating, the Manager-NOAD, may recommend to the Plant General Manager that the plant be shut down. The Plant General Manager has the final responsibility for the overall evaluation of all aspects and implications of shutting down an operating unit.
NOAD personnel who report to the Manager.NOAD, are independent of departments, sections, and employees responsible for performing specific activities, and ha,e sufficient authority and organizational freedom to identify quality problems; to initiate, recommend, or provide solutions through designated channels; and to verify implementation of solutions.
BG&E has established that the Manager-NOAD, should have at least six years of responsible experience in engineering, design, manufacturing, construction, quality assurance, or power plant operation, as well as a knowledge of regulations and standards related to nuclear power plants.
The organization of NOAD is shown in Chapter 12 of the UFSAR. The Manager NOAD, l
delegates the following responsibilities for accomplishing required quality assurance activities:
Planning and scheduling evaluations of vendor quality assurance programs.
DEM Performing receipt inspection functions including special receipt ins;xctions and;r
'qqO coordinating testing performed to accept commercial grade items, des gnated NSR =
g items or upgrade NSR items for use in SR applications. (5)
N Reviewing proposed changes to QA Program documents for compliance with h
regulations and licensing documents.
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OUALITY ASSURANCE PCLICY Revision 37 Directing the efforts of personnel under the Nuclear QA Program to develop, f
implement and coordinate the industrial safety and fire protection program for the CCNPP, and to plan, schedule, and monitor aethities directly related to safery, fire protection, and prevention.
Menacer-Nuclear Sunnort Services Denartment i
The Manager NSSD is responsible for training, nuclear security, onsite procurement coordination, procurement engineering, procedures upgrade, state regulatory matters, and staff services functions for CCNPP.
The organization of NSSD is shown in Chapter 12 of the UFSAR. The Manager NSSD delegates responsibilities for accomplishing the following activities:
Prosiding support to Managers in the Nuclear Energy Dhision to ensure their personnel are properly trained and qualified to perform their assigned duties, including those duties which implement the nuc! car OA Program. Training required by special work forces and contractors would be performed by the appropriate BG&E Department, and/or Host Company (vendor).
Distributing, and coordinating the preparation of revisions to the OA Program documents; collecting, storing, maintammg, and retrieving OA records for nuc! car power plants; maintaimng, controlling, and distributing drawings and technical manuals related to equipment, materials, and services for nuclear power plants; coordinating investigations concerning state regulatery matters; coordinating the efforts of Nuclear Energy Dhision personnel involved in the procurement of structures, systems, components, parts, and services related to the design, construction, fueling, maintenance, and modifications of CCNPP.
Establishing procedures to assure that SR and DNSR procurement documents identify
. 4hnical and quality requirements; procurement (SR and DNSR) documents recchc independent review and approval for the proper inclusion of technical and quality requirements; ensuring spare and replacement parts are suitable for their intended application (s); specification of critical characteristics and acceptance criteria for dedication of commercial grade items; specification of special storage requirements for gg age sensitive items, t A.
Ensuring that the operational, maintenance, licensing, and training aethities associated ROM with plant security are effectively implemented, and that nuclear security provisions g.b provide protection for personnel, equipment, and facilities at CCNPP against potential secunty threats.
Individuals supporting the CCNPP OA Program are designated as follows:
Vice President Fossil Enercy Division The Vice Pres!Jent FED, is responsible for ensuring that the activities'of FED personnel involved in CCNPP maintenance and modifications; Materials Engineering and Analysis; and raddogical environmental monitoring, meet the requirements of the OA Program. This responsibility is carried out through the Manager-GMD, and the Manager-FED.
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QUALITY ASSURANCE POLICY Revision 27
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b.
Basic Component An item either procured as a safety related item or as a commercial grade item which has been accepted and dedicated for safety related application. This term is synonymous with " Safety.Related Component *.
Designated Non. Safety Related A NSR item which BG&E has made a regulatory or c.
design basis commitment; or, for plant availability reasons, BG&E has implemented special controls to assure reliability. These NSR items are included within the quality assurance process, d.
Non. Safety Related - An item that does not perform a safety related function.
3.
The procurement method to be used for the item or senice:
Purchase Orders placed by BG&E persor.nel for items or senices intended for safety related applications and DNSR items and senices fall into two categories, Nuclear Grade Method procurement and Commercial Grade Method procyrement.
Nucicar Grade - Purchases that are designated to be placed with vendors that maintain a.
a 10CFR50 Appendix B quality program and supply items that meet the definition of Basic Component. The requirements of 10CFR21 will be invoked on the vendor under this method.
b.
Commercial Grade - Purchases that are designated to be placed with commercial grade vendors that supply items or senices thra meet the definition of Commercial Grade.
These iterns must be dedicated for SR use i y BG&E.
Ard/or se.rvt(fs Items" classified as DNSR will be purchased using the Commercial Grade Method with technical requirements established by an RDO.
Quaiiibd NSSD/NED prsonnel trained in quality assurance program requirements with RDO authmt,' revin safety.reinted and designated non. safety relatcd procurement documents for proper incia io 4 of ten nical and quality requirements. Personnel in NSSD/NED review safety.related and designated nom afety reiated procurement documents to ensure tha; the requirements stated therein are correct,inspectable, controllable, contain adequate acceptance and rejection criteria, and comply with the requirements of the procurement program. These reviews and approvals are documented prior to placement of the purchase order.
All changes made to procurement documents, including specifications and other technical attachments, are subject to the same levels of review, approval and control that were applied in preparing and processing the original documents.
Bids submitted to supply safety related items or senices receive the same review and approval cycle as used for safety-related procurement requisitions, Vendor Selection Personnel in NQAD evaluate vendors who provide SR and designated NSR items and services to -
venfy they can provide acceptable items and services.
Controls for Nuclear Grade Purchases Controls have been established to ensure that, before placement of 1. parihu c.rder under the Nuclear Grade method of purchase, there is evidence of the following:
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QUALITY ASSURANCE POLICY Revision 27 Commerrial Grade
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ge,c se es Since BG&E accepts the responsibility of verifying the conformance of commercial grade
- itRthey may be procured from vendors with no for nal quality assurance program. In this instance, BG&E dedicates the commercial grade item for SR use.
tctrd/or servtcc.
A survey may be performed of commercial vendors to assess what, if any documented controls are implemented in the manufacture ofit::ms or performance of services for BG&E.
Vendor controls evaluated ta be satisfactory may be invoked as requirements within the purchase order and may be used as part of the basis for acceptance of the item.
The depth of vendor evaluation varies according to the complexity and function of the item involved and to the role of the vendor in acceptance of the item.
Vendor Annroval Upon completion of the evaluation, satisfactory vendors are added to BG&E's AVL Re vendors on this list are evaluated on an annual basis and subject to re-audit or commercial grade survey on a triennial basis f o verify continued compliance with BG&E's requirements.
An auditing organization such as NUPIC, another utility, a contractor to BG&E, etc., may be used to verify that the vendor has developed and implemented a OA program that complies with 10 CFR 50, Appendix B or a commercial grade program that complies with the requirements of BG&E's procurement requirements or similar requirements.
When required by operational considerations, an order may be placed with a vendor prior to
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completion of the evaluation and approval process only after obtaining the Manager NSSD's approval. BG&E's acceptance of basic component items or services provided by an unapproved vendor is contingent on the subsequent NOAD evaluation and approval of the vendor as stated above.
Verification of Vendor Activities Vendor surveillance, and source verification activities are conducted by qualified NOAD personnel in accordance with written procedures or checklists. These procedures or checklists, along with the procurement documents, specify the characteristics or processes to be witnessed, inspected or verified. Personnel performing these activities are qualified to establish whether or not a vendor is capable of providing products of acceptable quality.
The depth and frequency of vendor surveillances, verifications and audits is commensurate with the complexity and function of the item or service and the ability of the vendor to provide the nermary assurance of acceptability.
When a vendor'a certificates of coaformance are used as part of the acceptance of an item or service, the validity of these documents is periodically evaluated and documented by the above mentionsd processes.
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QUALITY ASSURANCE POLICY Revision 27 Receint PMMD is responsible for receiving and storing materials, parts, and components.
055D-Additionally, NOAD-is responsible for performing standard and special receipt inspections and coordinating testing necessary to accept SR items, designated NSR items anc; commercial grade items for SR use.
Standard receiving inspection ofitems is performed to assure the following:
1, The item is properly identified and that this identification corresponds with the documentation received.
2.
Stated pachging, shipping and handling requirements have been maintained.
3.
Items have not been damaged, workmanship is of adequate quality, and the items are adequately clean in accordance with procurement document requirements.
4.
Documentation required by tho Purchase Order has been received and is reviewed to assure that the item conforms to the purchase order requirements.
Special reccidng inspection may be require if the item was not inspected at-the source; when requested by the RDO or: as part of the acceptance basis for commercial grade items.
NSS O A written record of the results of theNQAD receipt inspection and the disposition of received items is maintained as part of permanent plant records.
All SR and designated NSR ltems accepted and released for issue to a controlled storage area or released for installation or further work bear an acceptance tag and have documentation to support their acceptability. If traceability is lost or the documentation review is unsatistactory, an item becomes subject to the controls established for non. conforming items.
Non conforming items are identified and handled in accordance with Section 1B.15 of this policy and, when practicable, are placed in a segregated area to prevent inadvertent installation or use ur.til proper disposition is made.
Documentation BG&E procurement dcsuments require vendors to provide documen:ation identifying the purchased item and the specific procurement requirements that are met by the item.
Vendor inspection records or certificates of conformance attesting to acceptance must be_in the possession of BG&E before the item may be released for insiallation or use. However, an unacceptable item may be given a " Conditional Release" if there is reasonable assurance that it can be made acceptable after installation but before the system that contains it is considered operational.
Items released under " Conditional Release" must be controlled under the Non Conformance Report
. (NCR) system.
Vendor requested deviations from procurement document requirements, including nonconformances dispositioned "use as is" or " repair" must be submitted to BG&E for evaluat'on and approval of the deviation or a recommended disposition prior to shipment.
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OUALITY ASSURANCE POLICY Revision 27 l
1 B.8 IDENTIFICATION AND CONTROL OF MATERIAL &
PARTS.
AND COMPONEN'IS (5)
NSSDiNED personnel ensure that procurement documents require that SR and designated NSR items, including partially fabricated sub. assemblies, are identified and controlled to prevent the use of incorrect or defective material.
1 Requirements for identiGcation by use of heat number, part number, or serial number, or by other
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means, are referenced or stated in procurement dcx:uments. These documents require the identification to te placed on the item or in records traceable to the item so that the function and i
quality of the item are not affected. This identification is required to be maintained throughout i
fabrication,2torage, erection, installation, and use, tiOAD personnel ensure traceability information t
is correctly transferred w hen an item is sub-divided.
NC 1% 40 r
> Assigned PMMD personnel -:hase identify, store, and issue items as specified by procurement controls and provide for mWaing the integrity of items and their traceability to associated t
documents during storage and issue.
BG&E contractors and their sub-contractors (who are approved in work on site under their own QA i
program) are responsible for establisning and implementing programs in accordance with speciGed requirements for identifying and controlling maMrials, parts, and components under their l
jurisdiction.
!denJfic6ior. of items important to the function of SR and designated NSR structures, systems, and components can be traced to appropriate documentation such as drawings, specifications, purchase orders, rar ufacturing and inspection documents, deviation reports, and physical and chemical mill.
test repors.
BAMir!
SR and designated NSR items received at CCNPP are receipt inspected to verify that all
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requircments of the procurement documents have been met. If a discrepancy is observed, such as damage or missing documentation, information to the effect is recorded on the receiving inspection report, and the discrepant item is identined as such and placed in a separate " hold" area when pr9et, cable. If the itern i, ucceptable,it is identified to indicate acceptance and that it is approved for
'.orage or installation and use. When groups of items in storagc are subdivided, each subgro parately identified.
If an item is found to be or is made discrepant during processing, it is identified as such and placed in a separate area w hen practicable.
- Acceptance documentation i.s cquired to be traceable to a purchase order, drawing, specification, f
requisition number, or assembly. As individual items are assembled, installed, and inspected, their acceptance tag numbers are recorded in plant maintenance or operation records.
After completion of tests ar.d inspections, records that document test results and traceability are kept i
as part of the plant records.
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