ML20099G108

Applicant Exhibit A-47,consisting of Forwarding Summary Description of QA Program for Design & Const. Description Supersedes Program in App D to Psar.Index to Exhibits Encl

ML20099G108
Person / Time
Site:	Limerick
Issue date:	05/07/1984
From:	Bradley E PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
OL-A-047, OL-A-47, NUDOCS 8411270115
Download: ML20099G108 (43)

Text

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PHILADELPHI A ELECTRIC COM PAN '9 l 2301 MARKET STREET < ^

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PHILADELPHI A. PA.19101  !  ; if 7f sawAno e. causa.Js. h (21518414000

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CONAb5SbAMM.M RWOObPM A.CMlbbsMI C. MIRM M Abb v.n. Mans =Coaasb' June 10, 1983 i PAuLAusneACM a..e.vaset ... a. . ....

SOW A RO J. Cu bbsM. J R.

TMOM AS M. MabbsR. J R.

lasms4.M.ns==4 Regional Administrator Ragion I -

U.~S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406

( (. -Subj ec t: Limerick Generating Station, Units 1 & 2 Docket Nos. 50-352 and 50-353 ,

Dear Sir:

Pursuant to Section 50.55(f)(2) of the Commission's

, Regulations, enclosed are 3 copies of a document entitled

" Limerick Generating Station Units 1 & 2 - Summary Description of the quality Assurance Program for Design and Construction" c dated June 10, 1983. This document contains the current t description of the Quality Assurance Program being ' implemented for Limerick Units 1 & 2 for inclusion in the Preliminary Safety Analysis Report. It is identical in format to Appendix D to the Limerick PSAR and supersedes the Quality Assurance t

Program description contained therein. Differences from the i

PSAR description are identified by change bars in the right hand margin of the enclosed document. ,

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'" P Regional 'Adminis trator l Page 2 June 10, 1983 The Quality Assurance Program for che operations phase described in Chapter 17 of the Limerick FSAR is currently under review by the NRC staff. Following issuance of an operating license, changes to this program will be reported pursuant to the requirements of Sections 50.54 and 50.71 of the Cor. mission's Regulations.

Very truly yours, ,

ps >

Euge J. B diey EJB/pke Enclosures

'Q f. . ... Copy to: See Attached Service Lisc i

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cc: Judge Lawrence Brenner Judge Richard F. Cole (w/enciesure) e Judge Peter A. Morris (w/o.encicsure)

Troy B.-Conner, Jr., Esq. '(w/o enclosure)

Ann P. Hodadon, Esq.

(w/enciesure)

Mr. Frank R. Romano (w/o enclosure)

Mr. Robert L. Anthony (w/ enclosure)

Mr. Marvin I. Lewis (w/o enclosure)

Judith A. Dorsey, Esq. (w/o enclosure) .

Jacqueline I. Ruttenberg (w/o enclosure)

Thomas Y. Au, Esq. (w/o enclosure)

Mr. Thomas Gerusky * *

(w/o enclosure)

(w/o enclosure)

Director, Pennsylvania Emergency' . (w/o enclosure)

Management Agency Steven P. Hershey (w/o enclosure)

Charles W. Elliott, Esq. (w/o enclosure)

Donald S. Bronstein, Esq. .

(w/o enclosure)

Mr. Joseph H. White, III (w/o enclosure) -

David Worsen, Esq. (w/o enclosure)

Robert J. Sugarman, Esq. (w/o enclosure)

Martha W. Bush, Esq. (w/o enclosure)

Atonde Safety and Licensing Appeal Board (w/o enclosure)

(Un (~j Atomic Safety and Licensing Board Panel (w/o enclosure)

Docket and Service Section (w/o enclosure)

I beet V. S. Boyer (w/ Enclosure)

J. S. Kemper (w/ Enclosure)

3. L. Daltroff (w/ Enclosure) -

E. C. Eistner (w/ Enclosure)

P. E. Favlides (w/ Enclosure) (

• , E. E. Logue (w/ Enclosure)

3. E. Moore (w/ Enclosure)

3. D. Bonan (w/ Enclosure)

EES Chron (w/o Enclosure) e a b

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l 1.IMERICK GENERArING STATION UNITS 1 & 2 -

SUMMARY

DESCRIPTION O ,.

u OF THF.

t QUALITT ASSURANCE PROGRAM t

FOR .

DESIGN AND CONSTRUCTION O- t Jm!E 10,1983

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APPENDIX D OUALITY ASSURANCE PROGRAM TABLE OF CONTENTS D.1 INTRODUCTION D.2 GENERAL D.2.1 Scope and General Approach D.2.2 Organization and Definition of the Philadelphia Electric Company Quality Assurance Program D.2.2.1 First Level-Quality Control and Inspection D.2.2.2 Second Level-Quality Assurance Surveillance D.2.2.3 Third Level-Quality Assurance Auditing D.2.2.4 Program Plans b,$ D.3 PHILADELPHIA ELECTRIC COMPANY OUALITY ASSURANCE PEOGRAM D.4 FIRST LEVEL ORGANIZATION OUALITY CONTROL REOUIREMENTS D.4.1 Organization D.4.2 Planning D.4.3 Control of Special Processes, Tests, and Inspections D.4.4 Control and Identification of Material, Parts and Components i D.4.5 Control of Purchased Material, Equipment and Services i i . D.4.6 In-Process and Final Inspection

, D. 4. 7 - Control of Inspection Status i, D.4.8 Control of Measurements, Inspection and Testing Equipment-

.D.4.9 Handling -Storage, Shipping and Preservation D.4.10 Control of Non-Conforming Material, Parts, Equipment i or Workmanship

! D.4.11- Control of Quality Records i D.4.12 Corrective Action '

l .D.4.13 Control of.. Specifications, Drawings, Procedures ,and Instructions D.4.14 Quality Control Program Documentation l

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D.5 GENERAL ELECTRIC OUALITY ASSUPECE PROGRAM D.5.1 Management D.5.2 Preparation of Specifications and Drawings D.5.3 Procurement of Equipment D.S.3.1 Equipment Manufactured by Other Companies D.5.3.2 Components Manufactured by General Electric

- NEB 0 Departments D.5.4 Construction Site D.6 BECHTEL POWER CORPORATION OUALITY ASSURANCE PROGRAM D.6.1 Project Management -

D.6.1.1 QA Surveillance of Project Engineering Activities D.6.1.2 QA Surveillance of Construction Site Activities D.6.1.3 Auditing D.6.2 Engineering Department D.6.2.1 Preparation of Specifications and Drawings D 6.2.2 Procurement Activities

( ) ' r" D.6.3 D.6.4 Procurement Department Construction Department ,

D.7 DESIGN CONTROL D.7.1 Philadelphia Electric Company I D.7.2 General Electric Nuclear Energy Business Group D.7.3 Sechtel Power Corporation D.7.4 Engineering & Design Consultants 4 \

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APPENDIX D

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OUALI*tY ASSURANCE PROGRAM i

LIST OF FIGURES

. FIGURE NUMBER . TITLE D.1.1 Philadelphia Electric Quality Assurance Organization for Limerick Generating Station D.2.1 Quality Assurance Program Functional Organization und Coimmunication

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OUALITY ASSURANCE PROGRAM I

i LIST OF TABLES I

TABLE NUMBER TITLE D.2.1 Summary 0-Lisc I

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LCS APPENDIX D

, OUALITY ASSURRICE PROGRAM D.1 INTRODUCTION

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Philadelphia Electric Company has the responsibility to assure that the Limerick Generating Station Units 1 and 2 are fabricated and constructed in accordance with applicable regulations, codes, and specifications.

- Accordingly, Philadelphia Electric has established a comprehensive quality assurance program which starts with the initial station design

'and carries through all phases of equipment procurement, fabrication, 1 erection and construction. This program provides for review of spacifications i-to insure that necessary quality control requirements are included and 4

for tho' performance of quality assurance surveillance and audits to

-insure that specified requirements are met.

Philadelphia Electric has established an organization to implement this quality assurance program. The Philadelphia Electric Manager, Quality

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Assurance is responsible for coordinating the program to assure that all necessary quality control requirements and procedures are followed f'_

during all phases of design, shop fabrication, and site construction.

The main participants in this quality assurance program, other than Philadelphia Electric itself, are General Elec.tric Nuclear Energy Business Operation and Bechtel Corporation.

• 4 The Philadelphia Electric Manager, Quality Assurance is assisted by various consultants in monitoring the quality assurance performance of General Electric, the various divisions of Bechtel, and their subcontractors.

A chart describing Philadelphia Electric's organisation as related to

- the Quality Assurance Program is shown on Figure D.1.1. t 8? The QA program described herein is modified as applied to the design-and fabrication of the High Density Spent Fuel Storage Racks. -Philadelphia

' Electric Company shall be responsible for developing the equipment specification for the Spent Fuel Storage Racks, for evaluating bids, vendor selection and procurement for review of the vendor's design, and

.for' surveillance of the vendor up to the point of delivery at the construction *

. site, at which time the Hacks shall como under the Bechtel Construction QA/QC program. Philadelphia Electric Company shall issue procedures to, control activities affecting quality which are performed by Philadelphia 7 Electric. and for surveillance of the vendor. The ' equipment specificaton shall impose appropriate QA program requirements on the vendor.

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The Quality Assurance program described herein is modified as applied to the activities related to the Reactor Pressure Vessel (RPV) sufo end removal and replacement and the Feudwater Closure Welds to the Reactor Pressure Vessel safe ends. Philadelphia Electric Company (PECO) shall be responsible for daveloping the administrative and quality assurance requirements. for preparing and issuing purchase orders, for review and approval of the subcontractor's Quality Assuranco Plan and procedures, and for second level audit of the subcontractor's activities.

PEC0 shall issue proceduros to control the activities affecting quality which are performed by PECO and for audit of the subcontractor. The subcontractor shall issue proceduros as required by the purchase order to control choir activition which affect quality including first level inspection and audits. The technical requirements for the Reactor Vessel removal and replacement work are prepared by General Electric NE30. The technical requirements for the welding and nondestructive examination of the Feedwater Closure Welds to the Reactor Vessel safo onds are

' supplied by Bechtel Power Corporation. -

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D.2.1- Scope and General Anoroach

. The quality assurance progras described herein applies to those structures, systens, and components of reactor facilities which are essential to the prevention of accidents which could affect the public health and safety or to mitigation of their consequences. Those structures, systems, and components which are considered as "unneutiai" are listed in Table 0.2.1.

The quality assurance program starts at the initial design phase with development of specifications and/or nanocinted purchase documents which contain quiility control and inspection requirements, and proceeds through the selection of the supplier, annufacture of the components or systems, and erection and installation.

Specific quality control requirements cover such areas as material control, welding requirements, nondestructive testing requirements, provisions for comprehensive auditing of manufacturers' or constructors' efforts, the preparation and retention of quality control records, etc., and will be included, as appropriate, in the various specifications and/or associated purchase documents.

General Electric-NEB 0 and Hochtel, as Philadelphia Electric's design contractura, are responsible for seeing that the necessary quality control requirements are included or referenced in the component and construction specifications and/or associated purchase documents for which they are responsible.

I Where specifications include interfaces between major contractor responsibilities, quality' control requirements will be jointly established.

Specifications and/or associated purchase documents pertaining to the " essential" items receive at least one independent review for evaluation of quality control requirements.

• The selection of a component manufacturer or field erection and installation subcontractor is made only after it has been ascertained that his organisation has the necessary quality control capability and the qualified personnel to pro $de

, the level of integrity required for the equipment or construction involved.

The quality sentrol programs of component manufacturers, subcontractors, and Bechtel Construction are noras11y under the audit / surveillance of the Philadelphia Electric sentractor (CE-NE30 or Bechtel) which is reopensible for that pertion of plant design.

This quality assurance effort by the appropriate Philadelphia Electric contractor is in addition to the quality control and inspection' progress of the individual H annufseturer or site constructor. The purpose of this effort is to assure that.

l the work of the various asnufactusers and constructors is actually proceeding in i asserdense with the specification or other approved progran requirements. A description of the Quality Assurance Progress of General Electric and techtel is sentained in subsections D.S and D.6 respectively.

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' in addition, to assure that the quality assurance program is functioning as j desired, Philadelphia Electric conducts quality assurance audits on a spot-check sis, on the <ualier aro. e of cene i =1e i -#=>a. no

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D.2.2 Ornanisation and Definition of the Philadelshia Electric

.Ous11tv Assurance Prosras.

Figure D.2.1.is an overall functional quality Assurance Chart showing thu

. working relationships between philadelphia Electric and its contractors for the Linarick. Generating Station. This Quality Assurance Program is divided into three levels. These levels are indicated on the left hand side of Tigure D.2.1. The definitions and functionn of the three levels indicated on'the organisation chart are described in the following subsections.

D.2.2.1 First Level -'Ouality Control and Ins 9ection i The First Level is defined as the Quality Control and Inspection function.'

Component manufacturers are required contractually to have a quality control and Lspection pronrna. licchtel ConMeruction performs first icvol inspection on Bechtet site activities and selected on-site subcontract activities. Subcon-tractors are required to either provide a quality control and inspection program, or may have first level inspection performed by Bechtel Construction. Each inspecting agent has the responsibility to ensure that the fabrication / construction activities meet specification requirements.

For those cases that Rechtel Corporation Construction Division subconersets site construction work (e.g. Containment Vessel), the subcontractors are required to either provide a quality control and inspection program, or may have first level inspection performed by Bechtet. Construction. Sechtel Construction performs first level inspection en Bechtel site activities and selected on-site subcontract activities. Rechtel Construction performs a second level surveillance function

- -on the subcontractor's Quality Control and Inspection efforts when first level surveillance is performed by the subcontractor. In certain cases where the subcontractor provides first level inspection, the Bechtel (second' level) Quality Assurance or Quality Control surveillance function may not be considered necessary when Philadelphia Electric Company performs third level Quality Assurance Audits of a more comprehensive nature.

D.2.2.2 Second Level - Odlity Assurance Surveilla g The Second Level, which is defined as a Quality Assurs ce Surveillance function g

. includes auditing and/or surveillance, performed by the Philadelphia Electrie-eentraster (General Electria NE30 or Bechtel) which is responsible for furnishing the requirement specifications for materials, components, construction, and instal-

'lation which in turn are used by the first level groups.

When Sachtel Corporation Construction Division subcontracts site construction work, the Quality Assurance Surveillance function is normally performed by Bechtel Corporation. In certain casee where the subcontreeter provides first level inspection the Seahtel Quality Assurance second level Surveillance function may not be considerce necessary when Philadelphia Electria Company performs second or third ' level Quality Assuranse Audits of a more comprehensive nature.

. The Philadelphia Electric contractors which perform this second level function each have quality assurance capability which is used by their respective organisations in assisting in this quality effort. This quality assurance capability

(. includes personnel with technical backgrounds in appropriate disciplines (e.g.,

electrical, mechanical, civil).

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LGS L.2.2.3 Third Level - Quality Assurance Auditina The Third Level is defined as the Quality Assurance Auditing function performed by Philadelphia Electric. Selected QA Consultants assist l'hlladulplila Ciectric in implementing this program. The purpose of this quality assurance function is to ensure that the overall Quality Assuranca Program is functioning as plar.nsd.

To accomplish this, Philadelphia Electric reviews, prior to order placement, specifications and associated purchase documents furnialsed by thu dusign sentreetors (General Electria-NE30 and Bechtel) to ensure that the necessary quality requirements have been incorporated.in these documents. In addition, on a spot-check municoring bants, Philadelphia Electric performa quality nnnurance audits to ensure that the Quality Programs of the first and second level groups are actually functioning as required. ,

0.2.2.4 Proteram PInns Detailed descriptions of the Philadelphia Electric, General Electric-NERO, and TG sechtel Power Corporation programs which contain guidelines, criteria, organizationn!

'U g responsibilities, and other persinent informattun.for the implementation of chu

- Philadelphia Electric Quality Assurance program will.be contained in the following quality assurance plans.

=a. Philadelphia Electric Quality A=uurancu plan for Limurick Canuratina Station Units 1 and 2, Volume 1. .

b. General Electric-NE80 Boiling Water Reactor Quality Assurance Program Description, NEDO-11209.

c. Rechtsi Nucisar Quality Assurance Manual. g The foregoing QA plans used to implement the quality assurance program described in-the PSAR may be revised to incorporate improvements which evolve as emperience is gained.. These detailed quality assuranse plans will be available to NRC personnel 'as they perform audits to evaluate the implementation of the Philadelphia Electria quality Assurance 'rogram.

0.2.2.5 Aeolication of thu Ouality Anwursace l'rogram

-The Quality Assurance program has been expanded to include the following systems and/or items of activity.

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(1) Fire Proteccion

, The quality Assurance Program applies to fire protection equipment including fire sensing, fire supprossion, emergency lighting, and communication equipmenc in safety related areas and in the main turbine lube oil reservoir area.

(2) Base-Line Preservice Insoection

- This Quality Assurance pro'g ram-applies to the base line preservice inspection except that there will-be a two level program concept instead of three level for actual base line inspection activity at the plant. The firnt level will be the subcontractors, including surveillance and auditing as contractually, required. The Second Level.is the PECO quality assurance auditing functior, (3) Pre-onerational Test Phase

g. The Quality Assurance Plan applies to the Pre-Operational

s. , Test Phase with two exceptions. These exceptions are:

1) that PECO Electric Production Department is responsible for the direction of the preoperational and acceptance tests conducted by the Startup organisation and 2) the two level program concept will be used instead of the three level.

The first level is that of the testers (quality control)

- and the 2nd level is the PECO quality assurance auditing (and where appropriate) QC inspection functions. Based on the fact that the pre-operational test phase responsibilities cover both Engineering and Research Department.and the g-

, Electric Production Department activities, the audit responsibilities have been divided between the respective QA groups (Engineering and Research QA Section and Electric Production QA Division).

(4) Himh Density Soent Fuel Storane Racks 9

The quality Assurance Program ap' plies to the design 'and fabrication of the "as modified high density spent fuel storage racks.

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(5) Reactor Vessel Safo End Removal and Roniacoment and Feedwater Closure Weld to Reactor Vessel Safe End e

The- Quality Assurancu prograta is applied to the activities related to the Reactor Pressure Vessel '

(RPV) safe end removal and replacement and the

, , Feedwater Closure Welds to the Reactor Pressure Vussul safe ends as described in the Qua.11cy Assuraneu f.9 Plan. Philadelphia Electric Company (PECO) shall be u'

I responsible for developing.the administrative and quality assurance requinnents, for preparing and .

issuing purchase orders, fur review and approval of the subcontractor's Quality Assurance Plan and

. procedures, and for second lev'el audit of the

( subcontractor's activities. PECO shall issue procedures to' control the accivities affecting-quality which are performed by PECO and for c., S, audit of the encont accor.

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(6) E=ergency Resoonse' Facilities Data Acquisition M :r; <<

Svstem (ERFDS) 4 4 The quality assurance program is' applied to the purchass of the ERFDS as described in the Quality '

Assurance Plan. PECO-shall be responsible for developing

",i the purchase specification, for evaluating. bids, vendor selection and. procurement, for review 'of the

. vendor's design and for audit of the vender's design- ;3 and field activities.

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SUMMARY

0-LIST 1

I. Civil-Structural I Reactor Building ,

Primary Containment '

Diesel-Generator Building, Control Room Area

, Complex and Intake Structura Housing Critical Punps ,

Diesel Fuel Sturage Facilities l Supports for Nuclear Class I and II System Components

, Spent Fuel Pool II. Mechanical Reactor'Asser.bly Fuel Assembly Reactor Vessel Reactor Vessel Support

=() Reactor Vessel Stabilizer

, [~1 Shroud and Shroud Support, including Core Spray Sparger l Core Spray Line j _ Core Support i _ Top Guide l Orificed Fuel Support ,

l' Control Rod including Velocity Limiter -

l , Control Rod Drive Control Rod Drivu !!ousing Control Rod Drive Housing Support

-Jet-Pump' Assembly ,

Power Range Neutron Detectors t LCPI Coupling Flange l 1 Nuclear Boiler System Reactor Vessel Relief Valves

j. Reactor' Vessel Safety Valves Main-Steam Line Flow Restrictors _

Main Steam Piping and Isulation Valves  ;

i Main Steam Line Suspension- ,

Selected Instrumentation Selected Valves i

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l LCS Reactor Reci culation Svstem Recirculatten Pumps Recirculation Valves By-Pass Valves Recirculation Piping Recirculation Loop Suspension Recirculation Loop' Restraints Selected Instrumentation -

Control Rod Hvdraulic System Portions of the Hydraulic Control System necessary for Scram.

Standby Liquid Control Svstoms Standby Liquid Control Tank Accumulator Pumps Explosive Valves Selected Instrumentation Selected Piping, Valves and Suspension

'O r ' Neutron Monitorinz Svstem Intermediate Range Monitor Average Power. Range Monitor including Local Power Range Monitor Inputs i

Residual Heat Removal System .

' Heat Exchangers Pumps Selected Instrumentation g

- ' Selected Piping, Valves and Suspension

.RRR Service Water System RHR Service Water Pumps

- RHR Service Water Piping, Valves and Suspension Instrumentation ,

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Core Sorav Svstem Core Spray Pumps Selected Instru=entation Selected Piping, Valves and Suspensica High Pressure Coolant-Inie: tion Svstem EPCI Pump HPCI Turbine = ,

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Selected Instrumentation Selected Piping, Valves and Suspension Reactor Core Isolation Coolint System 1.

RCIC Pump RCIC Turbine Selected Instrumentation Selected Piping, Valves and Suspension Primarv Containment and Reactor Vessel Isolation Centrol Systen Trip Systems A and B

, g Isolation Initiation Channels

-- Incident-Detection Circuitry Core Standby Cooling Systems Initiating Channels and Logic Automatic Depressurization System Initiating Channels and Logic Dryvell Drain Isolstion Valves l-l Reactor Water Cleanuo System l t L Piping, Valves, Suspension and Instrumentation within Primary l Pressure Boundary Service Water Systems y Serving Engineered Safeguards Equipment Reactor Buildine Rocirculation System -

l c- Fans Duce Work and Pipe including Reactor Building Vent Valves and Dampers Instrumentation

! High Densirv Snent Fuel Storsee Racks

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t Standbv Gas Treatment Svstem Fans.and Filters Duct .*w'ork and Pipe Valves and Dampers Suspension System Instrumentation Cooling System for:

RCIC, HPCI RHR and. Core Spray Rooms.

Control Room Ventilation Suoolv Svstem .

Emereenev Switchcear Room Ventilation Reactor Bu11 dine Isolution Control System Reactor Building Recirculatlon System

. [ Primary Containment Atmosphere Control Svstem throu2h Isolation Valve

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Reactor Building Crane III. Electrical Standbv Diesel Conurator Including Cooling and Fuel Supply Systems g

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Electrical Power System Associated with Safety Related System Control Room Panels .(Safety Related)

. Local Panels and Racks (Safety Related) e e.%

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' LGS 3.3 PHII.ADEl.PHIA CLECTn1C COMPANY QUALITY ASSURANCE PROGRAM The Philadelphia Electric quality assurance program has been developed with the NRC quality ' assurance criteria as its basis. It provides a. systematic, controlled

=echod of applying applicable portions of the NRC criteria at all levels of the Limerick project and establishes a means of follow-up and evaluation to ensure that the intent of these criteria are actually met.

More specifically, Philadelphia Electric-requires of its contractors,. General Electric-NE30 and Bechtel Corporation, that they meet the provisions cf the NRC criteria and that the applicable requirements be invoked-upon their Vendors.

The plant constructor and site subcontractors,are. required to meet the same type of quality control provisions. This is accomplished as follows:

'a. Quality control provisions are specifically applied to first level vendors,-chrough a generic quality assurance specification (Bechtel '

Corporation) or specific quality control plans (General Electric) coupled with provisions of applicable specifications, drawings, and purchase documents. Thu contractors will designate the casential equipment depending upon such considerations as the safety related function to be performed, its importance to' the overall' system, and whether it is dupliented in redundant installncion. Approprince NRC criteria will be applied to each component.

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'The quality control requirements to be placed on key vendors, the constructor, and selected site subcontractors will be reviewed by Philadelphia Electric.

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c. The quality control capability of potential ~ vendors will be evaluated

. by General Electric-NEB 0 and Bechtel.

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d. The Philadelphia Electric three level quality assurance program identifies L a clear line of responsibility for' Laplementing quality" requirements apd -

, , provides a means for ensuring that the quality requirements specified l' are being met. This, the first level vendors, the constructor, and the j site subcontractors are required.to have their own inspection and ~

L quality control efforts to assure that specifications and other

j. requirement documents are met. The second level quality assurance audit or surveillance functions performed by General Electric-NI30 and Bechtel provides a means for ensuring the work carried out by the vendors, constructor,.and subcontractors meet specified requirements. Finally; L the third-level Philadelphia Electric quality assurance effort provides a separate and independent monitoring of the overall QA progr'am to L ensure that it is functioning as planned.

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's. Pertinent inspection, quality control, and quality assurance

' documentation will be maintained for this project.

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The Philadelphia: Electric Manager, Quality Assurance is responsible for coordinating the quality assurance program. The Philadelphia Electric Manager, Quality Assurance has the authority to stop work. The overall organization of this program is shown on Figure D.2.1 Philadelphia Electric will ' station Quality Assurance Engineers at the construction site to audit the conscr'ction u and installation work. These site Quality Assurance Engineers report to Philadelphia Electric Manager, Quality Assurance.

' Assistance from Philadelphia Electric Engineering and Rasearch Department engineers is available to the Manager, quality Assurance.

Varioua divisions of the Philadelphia Electric Company or consultants assist the Philaculphia Electric Manager, Quality. Assurance in monitoring the overall Quality Assuranc Program. Philadelphia Electric has retained selected QA

' consultants to assist ic monitoring this program. This assistance is in conjunction with the quality functions that are performed by Philadelphia Electric and its contractors and their subcontractors, as follows: ,

a. Review of specifications, drawings, procettures, inspection check-off lists, and other pertinent docutents to assure that the quality control and test require =ents for components and systums uru included.

b. Periodic quality assurance audits and checks at manufacturer's plants and at the site to evaluate the performance of Philadelphia

. g- Electric contractors and subcontractors in implementing the ..

( specified quality control and testing requirements and maintaining -

necessary records.

c. Witness, on a spot-check basis, tests on components and systems.

In the performance of the Quality Assurance tasks the QA consultants will advise the Philadelphia Electric Manager, Quality Assurance or the Philadelphia Electric site Quality. Assurance Engineers, as appropriate, of 'any deviations or deficiencies found during quality assurance audits of component fabrication and '

site construction, so that corrective action can be taken without delay.

Philadelphia Electric uses written procedures or checklists for reviewing

. documents and' performing quality assurance audits. The reviews, audits, and follow-up action are documented.

Beginning February 1983,-Philadelphia Electric initiated the performance of field quality control inspections. ,

These PECO QC inspections are performed on the various systems as completed by Bechtel and turned over to PECO for field test and calibration of instruments.

The inspections are documented on a Quality Control Inspection Checklist (QCIC) .

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D.4 FIRST LEVEL ORGANIZATION OUALITY CONTROL RECUIRD!ENTS When deemed appropriate ':Or Bechtel and' General Electric-NE30 the equipment vendors and subcontractors will be.raquired by the applicable equipment or construction specifications and/or associated purchase documents to have '

a quality control program. In addition, Bechtel Construction will have a Quality Control Program. These programs shall cover the necessary quality control requirements for.che fabrication, installation, testing, or construction of the =" essential" portions of the plant and shall include appropriate elements of the following items:

'D.4.1 Organi:ation I,

The vendor (in this subsection, the term " vendor" shall include Bechtel site

. subcontractors) shall have a quality control organization which has the authority and responsibility for seeing that the quality control program is established, planned and implemented. The quality control organization shall delineate its responsibility and' duties in writing and shall provide suf ficient organizational ifreedom_to permit identification of quality control problems anc initiation of appropriate corrective action.

D.4.2 Planning j The vendor,!during the' earliest ' practical phase of contract performance, shall

' conduct a review of the requirements of the contract and take timely action to

( ensure that necessary quality control procedures and provisions are established

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• in accordance with the applicable specifications, codes and. standards. In particular, the vendor shall make timely provisions for having the required qualified personnel available and written procedures of.this program in effect prior _to their actual use in manufacturing or fabrication of the item under contract.

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' Bechtel and General Electric will judge quality assurance programs against the quality assurance requirements invoked in the specifications and purchase orders.

In addition, Philadelphia Electric will monitor this work to assure that an adequate evaluation has been made.

I The adoquacy of thu implementation of these programs is assessed by the surveillancu or auditing performed by the second level. contractors. . Philadelphia Electric, through spot check audits, will evaluate the adequacy of implementation of vendor and second level quality nanurance programs.

D.4.3 Control of Soecial Processes. Tests and Insoections

1. The vendor'shall operate under a controlled manufacturing system and shall-have written procedures or instructions for control of special_ fabrication and construction processes such as welding, heat treatment, cleaning, control of tools and fixtures, weld electrode control, concreto production and placement, specisi equipment

. -- installation at the construction site, etc.

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2. - The vendor shall have written procedures for control of the required testing and inspection programs on the item under contrac:. These s_ procedures shall cover all nondestructive testing (radiography, magnetic particle, liquid penetrant, ultrasonic, etc.) weld fit-up inspections, soap bubble tests, hydrostatic tests, etc.

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D.4.4 Control and Identification of Material. Parts and Cemoonents

(- '

The vendor shall'have written procedures for assuring the control, identification, and location of materials, parts, and components used in che finished item under contract.

D . 4'.' 5 Control of' Purchased Material. Eculoment and services

- The vendor shall have written procedures to assure the control of purchased

- material, equipment, and services, including such items as purchase documents, receiving inspection, identification and certification of incoming material

.and equipment to insure that it conforms to the requirements of the purchase

- specification. In addition, the vendor is responsible for assuring that supplies and services procured from his subvendors conform to the contract requirements considered applicable. The vendor shall further provide for the submittal of-required quality plans and-documentation from his s.ubvendors and shall, as appropriate, obtain the right of suurce inspection

• and visicution for himself and/or his representatives.

D.4.6 in-process and Final Tnanection The vendor shall have written and documented In-Process and Final Inspection Programs for the item under contract. As a portion of these plans, tha vendor shall establish an inspection and testing plan, check-off lists, or

- other suitable systems to assure that required inspection.and tests are performed and to provide records of their ' performance. Such plans shall indicate, as appropriate, inspection points to be witnessed and witnessing organizations.

2 D.4.7 Control of Insnection Status

, The vendor shall have a system designed to assure that the current inspection

. status of the item under contract is known at all se, ages in the production process. This may be accomplished by means of stamps, tags, routing cards, multicolor tape, or other suitable methods.

- D.4.8 Control of Measurements. Inspection and Testina Ecuipment

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The vendor shall-have written instructions governing the control of measurement, inspection and test equipment. These instructions shall. include, as appropriate,

. calibration to standards traceable to nationally recognized standards, accuracy requirements, and recalibration frequency requirements.

Handlina. Storaae. Shinoina and Preservation D.4.9

1. Where-appropriate, equipment vendors shall have written instructions, to govern the handling, storage, shipping, and preservation of the

- items under contract so as to prevent degradation of the quality below that required by the applicable equipment specifications.

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2. Sinilarly, site installation and construction contractors shall have written instructions to govern the handling, storage, and

.' ' preservation of equipment prior to and after installation.

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1 D.4.10 Control of Non-conformine Material. Parts. Ecuinment or Workmanshio

-The vendor _.shall have written procedures governing the ident'ification, control, and disposition of materials, parts, or equipment that do not meet specification requirements. Repairs shall be in accordance with documented instructions. . Major. repairs shall be in accordance with documented procedures approved by General Electric or Sechtel.

D. 4. l l~ . Control of Onnlity Reco rd s There shall be written requirements governing the accu =ulation, storage, and disposition of appropriate manufacturing, installation, construction, inspection, test, and quality control records for the item under contract. There shall be a specific list of records which the vendor will turn over to General Electric or Bechtel'(as appropriate) for transmittal to Philadelphia Electric, and/or those which shall be maintained for the life of the plant (i.e., 40 years).

This list shall be in compliance with the contractual arrangement between General Electric and Philadelphia Electric concerning records to be provided to, or maintained for, Philadelphia Electric. The vendor procedures governing -

the control of records he retains shall describe what steps he will take.co ensure Lhat-Lhuse rueurdu will be adequaLuly storud and readily retriuvable for the life of the plant. Quality control records produced by Bechtel and obtained from vendors will be accumulated and turned over to Philadelphia Electric at the end of the job.

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D.4.12 Corrective Action i

l , The vendor's quality control program shall provide for quality information reporting to management and others having quality system responsibility l -concerning the overall status of product quality and Muality-related plans and programs. The program shall provide input for the initiation of corrective

-action and follow-up as appropriate.

D.4.13 Control of Specifications, Drawings, procedures, and Instructions t

The vendor shall have written procedures governing the control and use of

-specifications, drawings, and the various work, test, and inspection procedures.

The procedures shall indicate how the vendor assures that only appropriately approved versions of specifications, drawings and procedures are actually used by .his work force and inspection personnel. In addition, the vendor shall obtain the concurrence of General Electric-NEB 0 or Bechtel Engineering

'(as appropriate) to changes in specifications, drawings or procedures which ,

the latter originally prepared or, approved.

D.4.14 -Quality Control Program Documentation

. Quality control documentation of vendor work will be maintained in accordance with written requirements contained in the applicable generic quality control specification (Bechtel) or quality control plans (General Electric-NE30), individual specifications, and purchase order requirements.

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General Electric-NEBO and Bechtel will maintain the specified quality con:rol records supplied by their. vendors for the equipment they prepare (except for such records that code require =en:s specify the vendor =ust re: sin). I: is planned that .these records be :urned over to Philadelphia Electric.

Pertinent audi: and surveillance inspection reports, and the docu=entation of design reviews will be maintained by General Electric NE30 and Bechtel according to written provisions in their quality control plans.

Sechtel will document site work according to specific requirements con:ained in-applicable specifications and field quality control procedures. These records will' he compiled and turned over to Philadelphia Electric at the comple: ion of the project construction.

Philadelphia Electric will document audi:s and reviews of specifications, drawings and other technical requirements.

The vendor shall have documents which describe his quality control program and organization including administrative policies and procedures affecting quality.

The vendor shall make available, upon request, his quality control program documentation including the applicable procedures, records, and qualifica: ions

i. governing subsections D.4.1 through D.4.13 for review by General Electric cr l' . Bechtel (as appropriate) . li concurrence with these documents is requi red by the purchase order, the vendor shall not start work on a. specific task

-governed by a procedure until the procedure has been reviewed and cocmen:s resolved satisfactorily.

3O' l Manufacturing processing, testing, and inspection operations performed by l vendors and their subcontractors shall be subject to quality audit or L surveillance with respect to the contract w'ork by General Electric or

' Bechtel, as appropriate. Philadelphia. Electric and/or its agent, working through General Electric or Bechtel, shall be. accorded access for audi: or witness purposes. In this regard, any quality audit or surveillance by General Electric Hechtc1, or Philadelphia Electric and/or its agent shall not relieve the vendor ur subcontractor of any responsibility 'for meeting contract requirements. , ,

t D.4.15 Audit of the OA Proeram Surev111ance and auditing by the second and third level groups on the first level will be used to assure that the vendors are complying with specifications, L including the approrpirate NRC criteria as invoked in the order.

[ The'following is Bechtel's procedure for assuring that vendors are following

• the NRC QA criteria: , ,

a. Project Engineering prepares specifications and procurement documents l

telling the vendor what technical requirements have to be met and-requesting that the vendor describe his QA program showing how he will l satisfy the NRC QA criteria.

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b. Project Engineering reviews the vendor's program to see that it

, satisfactorily meets the NRC QA criteria and technical.;equirenants Ias set forth in'the specifica'tions.

c.. The requirements of the ' vendor's QA' program are included in the '

contractual documents and once the contract is awarded, the_vendo:

accepts responsibility to assure contractual commic=ents are =et including the applicabic NRC QA criteria and-technical requirements.

.d. To assure the vendor's shop' practices are meeting the cpplicable'NRC QA criteria and - technical requirements, Dechtel Procurement provides surveliiance of the vendors' shops.

The following isL Ceneral Electric's procedure for assuring that vendors are satisfying _the intent of the NRC QA criteria:

a. General Electric, previously and currently, has been applying appropriate-QC plans on vendor supplied equipment. These QC plans embody the appropriate requirements of the 18 QA criteria.

b .' General Electric will provide an audit or surveillance function of its vendors' wurh to assure that the specified qual Ley requirements are met.

[~) c.- Design control activities are documented in formal' Ceneral Electric b document nyntemn that require vendur cumpliance with dusinn erlteria

/-

' and submittal of designs, specifications, and designated vendo:

procedures to General Electric for review and approval.

Philadelphia Electric audits on a spot check basis the Coneral Electric NEB 0 and Bechtel efforts to ensure vendor compliance with che intent of the NRC criteria and similarly audits selected vendors, t

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D.3 -GENERAL ELECRIC 00ALIM ASSCPldCE PROGRAM The responsibilities of General Electric in this quality assurance program can be sum =arized as follows. (Also See Section D.3) i- D.5.1 Manauement General Electric-NE20 is responsible for establishing quality control requirements-for the equipment within General Electric-NEBO's scope of sup?ly and assuring that.such requirements are followed. General Electric-NE30 is also responsible for developing site receipt inspection storage, and installation requirements for " essential" components under l its scope of supply. . The prime General Electric-NEB 0 representative is r

the Project Manager who is responsible for liaison with the owner of project quality related matters. The Project Manager is' assisted in the accomplishment of the quality task by the following:

a. The Phnager of the Quality Assurance and Reliability Operation

.who reports to the Senior Vice President and Group Executive of the NEBO, is responsible for integrating the various quality assurance programs within MEBO. Tho Product and Quality Assurance Operation 'is a staff componant assigned responsibility. for defining intra-Division quality-related responsibilities and rslationships, fer establishing uniform quality-related procedures and_ practices-

.s r- at'the Division level, and for integrating, measuring and auditing the quality-related work across the entire spectrum of the BWR business as conducted by NEB 0 line organizations.

l The Quality Assurance Section Manager reporting to the Manager of the Quality Assurance and _ Reliability Operation, $s a staff position assigned responsibility for establishing, documenting and directing an overall quality system and for integrating, measuring, and auditing the quality-related work across the~ entire spectrum of the BWR business as conducted.by line components.

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. A BWR Quality Council, with the Manager, Quality Assurance Reliability Operation as Chairman, provides for intra-Division communication and integration of quality assurance policies, procedures and practices.

The BWR Quality Council consists of representatives from each of the contributing organizational components of the BWR business and regularly

~

L meets to review status of the overall quality system, to provide management i reports of quality related activities, and to plan future efforts.-

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b. Mansgers - NEB 0 Design Engineering and pplicat1on Engineering are.

L responsible for establishing overall quality objectives and quality

l. requirements and are -also responsible for conducting design control

! ., , for the overall system design.

c. . Manager - NE30 Quality Control - Engineered Equipment and Installation

(),- who is responsible for the quality planning and implementation for

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. General Electric /NEBO scope of purchased equipment, except for General Electric /NE30 manufactured equipment.

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LG5 DEP: L L(~ ~ ~- d. - Managers - Quality Control - In the Control and Instrumentation

'A Manufacturing, NEB 0 Manufacturing, and Nuclear Fuels Manufacturing who are responsible for the quality planning and i=ple=entation for

. chair-respective manufactured products.

- e. Site' Resident Manager _ who is responsible for supplying technical direction for field installation, preoperational testing, and start-up activities on General Electric /NE30 scope of supplied syste=s and-components. Aiding-him in some of this effort is'a Quality Control Site Representative who reports to the Manager - Quality Control -

Engineered Equipment and Installation.

The foregoing organizational. relationships are shown on the accompanying Figure D.2.1.

D.5.2 Preparation of Snecifications and Drawines General Electric /NE30 is responsible' for the specifications, drawings, and purchase documents for essential _ equipment within General Electric's scope of supply. These documents and drawings will incorporate applicable _ design PSAR commitments, code require-ments, and applicable quality control provisions as covered in subsection D.4 above.

In addition General Electric / NEB 0 prepares the necessary requirements for the receipt, inspection, and storage of components at the

? construction site _ prior to installation, and for their subsequent 4 1. ~ handling and installation. The implementation of these site

'. requirements is the responsibility of Sechtel Construction.

D.S.3 Procurement of Enuipment

- All components procured by General Electric /NE30,~whether they are manufactured in General Electric facilities or by other-4 manufacturers, will be subjected to two separate quality programs; one a quality control and; inspection program and the other a quality assurance audit or surveillance program.

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. _D.S.3.1 Equinment Manufactured by Other Companies A manufacturer for a given component is selected by General Electric /NEBO on the basis of a determination that the manufacturer

has the capability to fabricate the component to the desired level of integrity and that he has the necessary experience and an Jadequate quality control system.

4 .

. General Electric /NESO will perform quality assurance surveillance on components and materials procured from such manufacturers'to assure that specification and drawing requirements are being met.

This effort will be administered by General Electric /NE30's Quality Control - Engineered Equipment and Installation.

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LGS &Qrg D.5.3.2< Comnonents Manufactured hv Cencral Cloctrie "E30 Dennetments To confirm adequate control on components and caterials manufactured by other General Electric /NE30 Departments, the Manager Ouality

- Assurance and Rel iabil ity Operat ion will conduct qual ity assuranec audits of the quality control programs of those departments.

General Electric will coordinate the retention of quality records for the work they and their subvendors perform under the contractual arrangement with Philadelphia Electric.

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D.S.4 Construction Site .

General Electric / NEB 0 will have a site resident manager located at the construction site.- This resident manager reports to General Electric /NEBO's Project Manager and is responsible for providing technical assistance to Bechtel Construction for field installation of General Electric supplied equipment and systems. Also located at the construction site is n Site

- Quality Control Representative who reports to the Manager of General Electric /NE30's Quality Control - Engineered Equipment

~ - and Installation. This representative is responsible for

_(s,) ..

monitoring Bechtel Corporation to ensure that they nre implementing the General Electric / NEB 0 quality requirements for receipt

- inspection, storage, handling, and installation of General Electric supplied equfpment and systems. -The General Electric /SE30 Site OC representative does not perform a Second Level Ouality Assurance function as defined in paragraph D.2.2.2. His function is to monitor site activities for warranty purpose's only. He will report significant discrepancies to Philadelphia Electric and Bechtel through appropriate channels.

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LG3 N2U'.*1 D.6 BECHTEL PC'4E2 CORPOMTION CUAL!TY ASSURANCE PROGRAM Responsibilities of Bechtel Power. Corporation in this Quality Assurance Program can- be aummarized as follows (see also ' Section D.3): '

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The Division Quality Assurance Manager is responsible for overall technical .

direction of the Quality Assurance Program, including formulating and implemunting pulley, administration, and coordination of the Nuclear Quality Assurance Program, and administrative and technical directica of the Project Quality Assurance Engineer thru the cognizant Quality Assurance Manager. The quality Assuranco Manager is responsiblo -for providing overall coordinat ion ur Engineering, Procurement, and Construction. departments. in quality annurance activities to effectively implement the Division' Quality Assurance Program.

..The Quality Assurance Managers, who report to the Division Quality Assurance Manager, are responsible for direct supervision of the Ouality Assurance Program, and provide direction to Quality Assurance Engineers. They are responsible to.

assure coordination of Engineering,. Procurement and Construction in Quality Awurance at rivit les to effectively implement the program, in addlLlun. Lhey coordinate QAE's, review and evaluate Project Quality Assurance Programs, and

- audit the performance of the various programs. They provide an indpendent channel .for QAE communication to management.

D. 6'.1 ' Proiect Manasement The Project Manager has responsibility for the surveillance, evaluation, and reporting to San Francisco Power DiviJion Management, of the Engineering,'

Construction and Procurement implementation of the Project Quality Assurance Program. The Project Quality Assurance Engineer directs and controls the Project Quality Assurance Program. The Project Quality Assurance Engineer

' coordinates with the Project Manager and assists him by monitoring the quality engineering and quality control functions of the project engineering, construction and procurement activities; he provides the Project Manager _

t with periodic reports of his activitics. The Project Quality ' Assurance Engineer is assigned to the project by and receives technical direction and assistance from the Division Quality Assurance Manager thru a cognizant Quality Assurance Manager. Additional Quality. Assurance Engineers will be provided when required by the work load.

D.6.1.1. OA Surveillance of Project Engineering Activities

.The Lead Office QualLty Assurance Enginwur monitors Project Engineering;1n

. the implementation of the Quality Assurance Program and reports directly to -

the Project Quality Assurance Engineer. He may be assisted by Office Quality Assurance Engineers.

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Sechtel Project Management is responsible for monitoring to assure that the

. quality control requirements for the storage of components'and materials, and the installation and construction of the components and systems are affcetively implemented. TheLLead Site Quality _ Assurance Engineer assisted by a Staff of Discipline Quality Assurance Engineers is located at the construction site to monitor construction quality control activities.and reports directly to the l'rujuct Qus11ty Assurancu Engineur. The Site Quality Assurance Engineers are-the field representatives of Project Management _ and perform the second level-quality assurance function at the site. The Quality Assurance Engineers are assigned by, and administratively report to . the Quality Assurance Manancr.

The Quality Assurance Engineers perform quality assurance surveillance of field activities including engineering, quality control, and construction.

They review reports of non-conformances, perform surveillanco of construction

' inspection wurk, and monitor the implementation of the overall quality control program.

The Lead Site Quality Assurance Enginear has the authority tu stop field work for which Bechtel has direct construction responsibility, and can

, stop subcontract work through the Field Construction Manager in the event of non-conformance with drawings, specifications, and procedures for structures, systems, and units un the 4-l.ist. The Quality Assurance

, Engineers also serve as field contacts for Philadelphia Electric Co=pany's l' Quality Assurance organization and others concerned with quality assurance in the field.

1 The reports of the Bechtel Quality Assurance personnel concerning the

, monitoring of the constructor's quality control ef fort will be a part of the quality control aistory file for the plant and will be turned over to Philadelphia Electric upon completion of the plant.

i D.6.1.3 Auditina Mut Quality Assurance Program provides a comprehensive system of Project and Management audits of project engineering activities; field engineering, construction, and quality control inspection activities; and the Procurement i

. -Departmant activities as they relate to the Limerick Project.

All of the above are carried out, c a sampling basis, periodically, during the design and construction period At the completion of construction for systems and structures subject co the Quality Assurance Program, a final inspection is performed on the work and associated quality assurance records to assure that necessary inspections and records have been prepared and are on file. A final inspection report is prepared confirming this finnt examination '

and audit. -

.Bechtel's procedures for conducting and documenting results of management-type QA audits are summarized as follows:

a. General Audits are conducted on an annual basis commencing after award of contract or construction permit. Random unscheduled audits are conducted

..( ) j' as conditions warrant or as requested.

D.6-2

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b. 'A general audit' plan, including appropriate check lists,~is prepared defining areas to be audited. This plan is developed in a preaudit meeting with Proj ect Engineering, ' Procurement, or Construction, depending en the type of audit,-and QA management.

^c. 'An audit review discussion is held with Engineering, t' rucu remen t , or Construction, as appropriate, to discuss the findings and obtain scheduled commitments to complete any necessary corrective' action.

1-

~d. .A report of the general audit noting deficiencies, recc =endations and general comments is prepared and distributed to Division Management, and to

- Engineering Management, Procurement Management or Construction Management, as

appropriate, and the Project Manager.

, e. The responsible Quality Assurance Engineer formally reports, every month i- to the Qiud Ity Assurance M:mager-Audits on the status or itumn requ i r ior, action until all items are closed.

D.6.2 Engineering Department

^

'As plant design contractor for Philadelphia Electric, the Bechtel' Engineering Department, through its Project Engineer, is responsible for establishing quality -control and quality assurance requirements for equipment and :.ntorinIs, other than those in the Cunural Electric NSSS scope of supply. This includes

preparing or approving detailed procurement, storage, erection, construction and test specifications and assuring that the design is performed in accordance with the Quality Assurance Program.

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0 - - A The Project Engineer is assisted in the quality effort by Bechtel Engineering's Chief Engineers of various disciplines who report'directly to higher nanagement and as such are not dircetly a part of the Project Engineering conm.

In assisting the Proje'et Engineer, Chief Engineers id the Engineering Department l are responsible for reviewing appropriate specifications, drawings, and purchase .

documents to.annuru that they includu applienble code and quality control <

requirements as well as PSAR requirements.'

i The Supervisor of Quality Engineering reports to the Manager of Engineering

'and assists him in carrying out his quality functions for Engineering.- The

, responsibilities of the Supervisor of Quality Engineering include defining and preparing Quality Program proceduros for the Engineering Department, assisting Chief Engineers in establishing standard quality practices for the technical disciplines and assigning and training Quality Engineers.

A Project Quality Engineer La assigned to the Project Enginuuring Team by the Supervisor of Quality Engineering to implement the Quality Engineering Program.

Assisting the Project Qiutlity Engineer are Quality Engineers who report to and receive direction from him. The Project Quality Engineer and the Quality Engineers

. receive administrative supervision and quality program direction from the '

Supervisor of Quality Engineering. The Project Quality Engineer receives project direction from the Project Engineer. Tea duties of the Project Quality

, Engineer and the Quality Engineers include final acceptance of Supplier Quality Assurance Programs, participation, as necessary in Supplier Quality Assurance

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/~T audics, and. revicv of engineering specifications prepared for Q-listed material',

(-) equipment,' structures, systems, and components and for services affecting the. quality of Q-listed material, equip =ent, structures,-systems and co=ponents.

Quality Cngincuring Coordinators (QEC's) are appointed, as necessary by Discipline Group Supervisors to assist Discipline Groups in providing the .

required coverage in quality engineering program details. QEC's receive direction relating to the quality engineering program from the Project

.. Quality Engineer through the Discipline Group Supervisors.

A Quality Engineering history file for work within Bechtel Engineering's scope of effort will be maintained by Bechtol. -This file will be transferred to Philadelphia Electric et the complation of che plant.

D.6.2.1 Prenaration of Soecifications and Drawings

= Engineering is responsible for -preparing specifications for Q-Listed equipment (except for the nuclear compenants supplied by General Electric). It is also responsible for preparing construction specifications, drawings, and project installation requirements. These documents and drawings will incorporate applicable design, PSAR, and-code requirements, and quality assurance provisions.

D.6.2.2 Procurement Activities With the exception of the Nuclear Steam Supply System, Philadelphia Electric or Bechtel will purchase Q-Listed equipment and material to specifications

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and drawings prepared by Bechtel or PECO Engineering. A manufacturer for a given component will be approved by Philadelphia Electric only af ter nechtel has 7

g' ascertained the manufacturer's capability to fabricate the component ~ to the desired level of quality and has determined that he has an adequate quality control capability. Once a manufacturer is selected, Hechtel Power Corporation will perform quality assurance surveillance on components and materials procured from such manufacturer to assure complianceiwich specification requirements.

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D.6.3 Procurement Dcoartment t

.- The Bechtel Procurement Department has the responsibility to perform a quality assurance surveillance function for Philadelphia Electric on the

! procurement of purchased items which are outside of General Electric NSSS l scope of supply. Hechtel Engineering and Philadelphia Elcetric have the primary responsibility for vendor evaluation und selection. Some of the contracts for. procurement of such components are processed under Philadelphia

! Electric purchase orders and others are processed under Bechtoi purchase j orders. Regardless of whether a Philadelphia Electric or Hochtel purchase

, order is used, Hechtel Procurement still performs the quality assurance

! surveillance function to assure that equipment manufacture is in compliance l with applicable specifications.

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LC 14ar?': L Bechtel Procurament Supplier Quality Department carries out the surveillance

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1{' }; function. utilizing established guidelines and procedures. Check-off lists describing the. specific areas which:should be monitored will normally-he

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employed. .These check-off lists represent the minimum amount: of - surveillanca that must be performed. Depending upon,the circumstances, the'Bechtel survelliance personnel, at. their discroclun, may do more and will report on the additional surveillance performed. Vhere necessary Bechtal Engineering personnel assist Bechtel Procurement in performing the surveillance effort.

D.6.4 Const ruction Denartment Bechtel Construction; Department through its Field Construction Manager is responsible for construction of the plant to approved engineering specifications, drawings and procedures. The Field Construction 4bnager has the prime authority

, andi-responsibility for Construction, Field Engineering and Subcontractor activities in the field. Site construction procedures ~ may be prepared to supplement Division . Construction and Engineering direction for activities affecting quality.for Q-Listed equipment. Such procedures will be reviewed and~ approved by Bechtel Construction.

The : Project Field Engineer is responsibic to the Field Construction Man mer for supervision of field engineering activities at the jobsite. In performing this function, he assigns qualified Field Engineers through the associated. Land 4

Discipline Field-Engineer within each discipline to provide engineering i direction and monitor . construction activities. The Project Field Engineer is responsible for the accuracy and completeness of engineering documentation, ascertaining that work is properly performed, and that defects are removed i and repairs are carried out in accordance with the applicable codes, engineering drawings, project specifications, and quality control procedures. He maintains

. liaison with project ' design engineers.

I The Disciplin'e Field Engineers report through the Land Discipline Ficid itngincors to the Project Field Engineer. They receive technical direction from tne respective Lead Discipline Engineers for field engineering functions.

l' The Chief Construction. Quality Control Engineer superviscs the Construct ion Department Quality Control Program and reports to the Manager of Division Construction. He is responsible for technical direction and administration ofl Field Quality Control Engineers. The Construction Field QualityLControl ,

, Engineer is assisted by the Quality Control Supervisor (s).

The Project Quality Control Supervisor for Limerick ' reports directly' co the -

Chief Construction Quality Control Engineer. He coordinates quality control activitics with cugineering and construction personnul. lie also providus technical support and monitors the performance of the Project Field Quality Control ' Engineer.

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_The Project Field Quality Control: Engineer (PFQCE) reports through the ,

Quality Control Supervisor to the Chief Construction Quality Control

. Engineer. The PFQCE supervises the quality control and inspection functions and sees that the quality of the work is properly inspected and documenced.

The PFQCE provides direction and supervision of testing laboratories and is responsible for the maintenance and safeguarding of the field quality files.

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~The=??QCE has authority to stop work. This authority, exercised through1 the Project Construction Manager, shall require i= mediate cessatica of work

. operations or construction activities determined to be improperly controlled and where corrective action would be extensive or may not be. fully. effective.

He shall assign personnel to establish and maintain the system to control

=easuring and test equipment.

The Quality Control Engineers and Technicians report to the PFCCE. They are

, responsible for preparing Inspection Plans' in accordance with the Field Inspection /QC Notices Manual, perfornine. Quality Control in.'pections includinn finai acceptance of Llie work initiatiny, and processing ur Noncont'ur:iuance Kuports and performing overall construction surveillance including caterial control ' .

- Precedures used to control and perform inspections by Ouality Centrol Engineers and Technicians will be. reviewed and approved by Philadelphia Elcetric- Company.

When site construction work is subcontracte'd the Project Field Ouality Control Engineer (PFQCE) performs the quality control surveillance fune:1on on such site subcontractor's work.

A~~ quality control file maintained for Bechtel work will be available for-Philadelphia Electric review. At the completion or the job it will be turned over tu Pisi tatielpliia Elect ric for thei r quality cont rol bl.6tury file of Live

-plant.

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--D.7 ~ DESIGN CONTROL

. D . 7 .' l . Philadel phin l'1ect rie Comnanv'

.The basic responsibility for design control. has been assigned to 'licchtel sad General Electric-NEB 0 for work in their specific areas of respcesibility.

. Design reviews are performed internally uith experienced personnel not

'directly associated with the original design effort.

In additon, Philadelphia Electric will, through .its Manager, Ouality Assurance audit the design efforts of General Electric-NEB 0 and Bechtel to assure that they are in fact operating in accordance with an adequate design controll

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system.

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The Philadelphia Electrie design review effort includes'the review and approval of the 'PSAR to ' assure it establishes proper desian criteria and providus an adequate design description of the plant. The design review performed by Philadelphia Electric also includes the review of specifications

• /-1 . and ~ appropriate back-up information to assure that the pertinent codes, e

i standards, PSAR requirements and quality requirements have been incorporated.

Specifications will be ruviewed by Philadelphia Electric, Engineering and Research-Depertment engineers.and perscnnel of the Operating Department, as-appropriate, to ensure compatibility between components and systems, ~ adequacy-

' of material seicettons, acceptability of installation, accexs und maintenance

. requirements, and evaluation of special design provisions or requirements.

Written comments are' returned by Philadelphia Electrid to the General Electric-h ._

-NEB 0 Project Manager or the Bechtel Project Engineer. -

This review will include but' not be limited to: 'the reactor coolant system-and its directly. associated auxiliary systems,.the containment system, the engineered safety featurcs, the fuel handling system, the radioactive waste t

. disposal system and plant accessibility for maintenance and inspection. -

Unresolved interface questions between contractors would be resolved by

, participation of -Philadotphia Electric.

D. 7. 2 , General Electric Nuclear Enerav Business Oneration 3 -

? The General Electric Nuclear Energy' liusiness: Operation (General Electric-NE30) has contracted for the design, manufacture and-delivery of .the Nuclear Steam Supply System as-defined by contract. As part of this work, General Electric NEB 0 has an internal design control program covering work -'

within its scope of responsibility. Design review is carried out by

- , individuals not involved directly.with the original design work.

( , For equipment procured by General Electric-NE30 for which it does not have

( the lead design responsibility, General Electric-NEB 0 will review and audit

'its subcontractors' design efforts with a frequency and depth consistent with

_the application of their equipment.

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-A=ong theLite=s included in the General' Electric-NE30 design centrol effort

!are the fcilowing:

a.

Determine that che' required design bases, PSAR commitments and.

other regulatory reqirements are incorporated properly .into' the design drawings, specifications, and portinent procedures and instruccluns,

b. Independently review to verify the adequacy of the design of-equipment and systems provided by General Elcetrie-Nr.no throunh review of drawings and specifications.

c. Identify required acceptance criteria for test and inspection.

d. Assure-that the design and support data _for nuclear related portions of the plant under General Electric-NEB 0 cognizance - are accurately-described in - the PSAR and FSAR submi ttals.

D. 7.'3. Bechtel Cerooration e ~~~

,. The .Bechtel Corporation as archttuct engineur for this project hus the s~ *

( responsibility.for the design and related-procurement effort for components i and equipment within its scope of responsibility.

As part o'f this werk, Hechtel Engineering has an internal design contrelLprogra=

covering work within its scope of responsibility. Design review is carried out by individuals not involved directly with the original design work.

For equipment . procured by ncchtel for which it does not have the lead design

. responsibility, Bechtel will review and audit its subcontractor's design efforts with a frequency and depth. consistent.with the application of the t equipment.

Among the items included in the Bechtel Engineering design control effort are the following:

a. Determine that the required' design bases, PSAR commitments and other regulatory requirements are incorporated properly into the design drawings, specifications, and pertinent-procedures and instructions. *

b. Independently review to verify the adequacy of Bechtel designed structures and systems through review of associated calculations, drawings, and specifications. This would include such areas as stress and thermal design analyses, material compatibility, seismic analysis and design interfaces.

c.

= Assure that the equipment systems are accessible for maintenance

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Id. Identify required acceptance criteria for tes:-and 1nspe:: ion.

e. L Assure that the design and support data for nuclear related por: ions.of.the' plant under Bechtel cognizance are accura:ely v

-described in the PSARiand FSAR submi :als. . _

!!cciatel has a formallzcd pro;; ram used in the design control. activition undur

,its responsibility.

13.7.4 Eneineering and Destin Consultants Philadelphia Elec:ric will. utilize the capabilities of design and engineering consul: ants to provide design review in specialized areas.

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