ML20099G117

Applicant Exhibit A-48,consisting of Forwarding Revised 830610 Rept Summary Description of QA Program for Design & Const. Rept Revised Per 840804 Discussion & Request

ML20099G117
Person / Time
Site:	Limerick
Issue date:	05/07/1984
From:	Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
OL-A-048, OL-A-48, NUDOCS 8411270124
Download: ML20099G117 (8)

Text

.

/ :gxp L . b . M l/ .. ..

O J ~ d .w$,)%

I ' PHILAD ELPHI A ELECTRIC COMPANY

?tc #

, 2301 MARKET STREET , g

._ _. . P.O. ECX 8699 /

PHILADELPHI A. PA.19101 5 El 4~C*

,2 % , . u ,,, g

. .u .... es.n e r. ,

is:=i s414 cc 2 . ;

9g# _

.\ _

........................ Septencer 1(t. 1 y

/ .x 2agionsi Ad=inistrator 6. ' . , l,

_.../ o iu;', ion 1

. .. S. Leiear acaulatory Co:::=1ssion / " 5 # I ' r. V 531 ?srk Avenue

' ting of Prussis, PA 19406

Subject:

Limerick Ganarsting Station, Units 1 and 2 Dockat Nos. 50-352 and 50-353 Refuruncus: 1) E. J. Bradley to Regions 1 Adminiscrstor letter dated June 10, 1983

2) Tht=ss T. Martin to J. S. Kemper letter dated Au;ust 10, 1983 Das: Sir:

The raf arance 1 laccer transmitted a document entitled "Lisarick g Canarsting Station, Units 1 and 2 - Suzansry Description of the Quality Assurance Progrs= for Design and Construction" dated June 10, 1983.

Subs 4quent to your staff's review of the reference 1 letter, s -

discussion was held with our staff on August 4,1983. The reference 2

' latter was sont identifying the sections of the Quality Assurance Progrs= Description (QA?D) which were to be revised as a result of the discussion. Those sections of the QAPD are being provided 4.c.this

( time in order for your staff to completa chair review.

Sincerely, A T- 4 .

l l

l LN/gra/D-9

• Enclosures Copy to: Sea Attached Sarrica List ,

I

's. .

l L) .  : '

l 0

m

- ~

kip l Z

'[~T - Judge Lcwrence Brenner enclosure)

(w/

'/

Judge Richard F. Cole (w/o enclosure)

Judge-Peter A. Morris (w/o enclosure)

Troy 3. Conner, Jr. , Esq. (w/ enclosure)

Ann P. Hod gden,~E;,q. (w/o cnclu.4urc)

Mr. Frank R. kcmano (w/ enclosure)

- Mr. R:' car: L. An:heny (w/o enclosure).

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

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

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

Jacqueline !. Ru:cenberg (w/o enclosura)

Thomas Y. Au, C.,q. (w/o onclosurc)

Mr. Thomas Gerusky (w/o enclosure)

Direc:or, Pennsyl.ania Energency M:nage:en: Agency (w/o enclosure)

Mr. S:even P. Hershey (w/o enc 1:sure)

Angus Love, Esq. (w/o enclosure)

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

David Warsan, Esq. (w/o enclosure)

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

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

Spence W. Perry, Esq. . (w/o enclosure)

Atomic Safe:y and Licensing Appeal Soard (w/o enclosure)

Acc=ic Safety and Licensing Board Panel (w/o enciesura)

Docket and Survice Suc:iun (w/o enclosure)

JY U

(

e 4

5 e

J.

. 2830602320 f) W: 2.

.= LGS e

D.2 cis_aAL

[~, D.2.1' Seone and General Aooreach 1

he quality assuranca program described herein applies to these structures, systems , .and components of reactor facilities which are essential to the prevention of -accidents which could. affect the public health and saf ety or to mitigation of their consequences. Those structurcs, systems, and conponent.

l i which -are considered as " essential" are listed in Table D.2.1, in sus =ary.

p Details are .shcwn in~ the Project Q-1.ist and the Quality Assurance Diagrs=s (QAD's).

4 The quality assurance program starts. at the initial design phase with development i of specifications and/or associated purchase documents which contain quality control and. inspection requirements. ,and proceeds through the selection of the

- supplier, manuf acture of the components or systans, and erection and installation.

cJ

' . Specific quality control requirements cover such areas as material . control, i

welding requirements, nondestructive testing requirenants, previsions for

cc

nprehensive auditing of manufacturers' or constructors' ef forts, the preparation and retention of quality control records, etc., and will be included, as i

' appropriate, in the various specifica tions and/or associated. purchase documents.

s General Electric-NE30 and Bechtel, as Philadelphia Electric's design contractors ,

s

- are responsible for seeing that the necessary quality control requirements are i-included or referenced in. che component and cons truction specifications and/or

f. associated purchase documents f or which they are responsible.

Where specifications . include interfaces between major contractor responsibilities, j .,

quality. control requirements will be jointly established.

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

c The selection of a component marnfacturer or field erection and installation subcontractor is made only af ter it has been ascertained that his organization I

. ' has the necessary quality control capability and the qualified personnel to provide i

the level of integrity required f or the. equipment or construction involved. '

The quality control programs 'of' component manuf acturers, subcontractors, and Bechtel 4

"' Construction are normally under the audit / surveillance of the Philadelphia Electric 2: contractor (GE-NE30 or Bechtel) which is responsible for that portion of plant design.

This quality assurance effort by . che appropriate Philadelphia Electric contractor ,

' is in addition to.the quality control and inspection programs of the individual

' manufacturer or site constructor. The purpose of this effort is to assure that the work of the various manuf acturers and constructors is actually proceeding in

~

accordance with the specification or other ~ approved program requirements. A description of the Quality Assurance Programs of General Electric and Bechtel is contained in subsections D.5 and D.6 respectively.

In addition, to assure that the quality assurance program is fun :ning as desired, Philadelphia Iloctric conduc .s quality assurance audits . a spot-check basis, on the quality programs' of General Electric-NE30, 3echtel and their

j. . subcontractors .

D.2-1 Sept. 1963

283060232C MSP

~

.1 D.2.2 Organ 1:stien and Definition-of the Philadelohia Eleerrie Quality Assurance Program

~

Figurs D.2.1--is an overall fune

ional Quality Assurance Char: showing the working relationships be:veen Philadelphia Electric and 1:s contrac: ors for

he Limarick Genera:ing S ts:ica. This- Quali:y Assurance Program is divided

in

o three levels. These levels are indica:ed on the lef: hand side of Figure D.2.1. The definitions and functions of the three levels indicated on the organization chart,are described in the following subsections. l D.2.2.1 First Level - Ous11:y control and Inseee: ion The First Level is defined as the Quality Control and Inspection function.

Ccmponent manuf ac turers are required contractually to have a quality con:rol and . inspection program. Sechtel Construction psrforms first level inspec:icn on

.Bechtel site activities and selected on-site subcontract ac:ivities. Subcon-

. tractors are required to either provide a quality control and inspection progra,

. or may have firs t level inspec tion perf ormed by.Bechtel Construc tion. Each

. inspecting agent has the responsibility to ensure that the f abrication/ construction accivities seee specification requiramenes.

For those cases that Bechtel Corporation Construction Division subcontracts site construction work (e.g. Containment Vessel), the subcontracters are required :o either provide a quality control and inspection program, or may have first levol inspection performud by Bu:htol Construc tion. Bochtel Construecion purforms iirs t level inspection on Bechtel site activities and selected on-site subcon::ac:

ac tivities . Bechtel Construction performs a second level surveillance function

'O-g surveillance

=a *====r === a 21=v c == t d Ia a ==1 = "

• a 't = t v t is perf ormed by the subcontractor. In certain cases where :he u :ubcontractor provides first level inspection, Philadelphia Electric Cerapany =ay elec:

to retain responsibili:y for both second level and third level Quality Assuranca audit /

.surveillanca activities, where Philadelphia Electric Company has a particular interes:

l in the sub-contractor. In those cases Philadelphia Electric Company will imple= ant

[ mora caprehensive Quality Assurance audits than the normal third level ac:1vi:y would require.

D.2.2.2 Second Level - Quality Assurance Surveillance The Second Level, which is defined as a Quality Assurance Surveillance function I -

includes aaditing and/or surveillance, performed by the Philadelphia Electric ,

contractor (General Electric NEB 0 or Bechtel) which is responsible for furnishing the f

requirement specifications f or materials, components, construe:1on, and instal-lation which in turn tre used by the first level groups. .

When 3echtal Corporation Construe:1on Division subcontracts site construction - '

wcrk, the Quality Assurance Surveillance function is normally performed by Bechtel Corporation. In certain casos where the subcontractor providos first level inspec' tion, Philadelphia Electric Company may elect to retain responsibility for both, second level and third level Quality Assurance audit / surveillance activ1:ies, where Philadelphia l- Electric Company has a particular interest in the sub-contractor. In these cases '

! ?hiladelphia Electric Company will implement more comprehensive Quality Assurance audi:s . than the normal third level activity would require.

The Philadelphia Elec:ric contractars which perform this second level function each have quality assurance capability which is used by their respe:.:ive crgani:ations in assisting in this quali:y effort. This quali:y assuranca capabili:y  ;

includes personnel with techn:, cal backgrounds in appropriate disciplines (e.6. , '

alse:::.:al, mechanical, civil) .

(' D.2-2 Sept. 19S3

1

~

2830602320

. psf: ?_

Q 103 c,

~

D . 2. 2.3 Third Level - Ouality Assurance Audi-in::

.Thein hrd Level is defined as the Quality Assurance Auditing function perf ormed-by' Philadelphia Electric. Selected QA Consultants assist Philadelphia Electric -

- in implementing _ this program.1 'The purpose of this quality assurance f unction is to' ensure that. the averall Quality Assurance Program is functioning as planned.

To acciznplish this, Philadelphia Electric reviews, prior to order placement,

- specifications and associated purchase documents furnished by the design

, contractors .(General Electric-NEBG and Bechtel) to ensure : that the necessary

- quality requirements have ,been incorporated in these documents . .In addition, on

a. spot-check monitoring basis , Philadelphia Electric perfums quality assurance

, au'dits' co -ensure that the Quality: Progr=2 of the firs t and second level grcups are actually functioning as required.

( ,

D.2.2.4~ Prost ram Plans -

O4?^ _ Detailed descriptions of the- Philadelphia Electric, . General- Electric-NE3G, and Bechtel Power, Corporation programs which contain' guidelines , criteria, organizational c

responsibilities ,. and other pertinent information f or the implementa tion of the' Philadelphia- Electric Quality Assurance program will be contained in tha following

. quality assurance plans.

La . , Philadelphia Electric Quality Assurance plan for Limerick Generating ,

Station Units 1 and 2, Volume I. , (Latest Revision)-

.b. General Electric-NEEG Boiling Water Reactor Quality Assurance Program

!; Description, NEDO-11209, (Latest Revision) l- t

. .c. Bechtel Nuclear Quality Assurance Manual, (Latest Revision).

The f oregoing QA plans used' co implement the quality assurance program described in the PSAR may-be ravised to incorporate improvements which evolve as experience

- is' gained. These dutailed quality essurance plans will be available to NRC

. personnel as ;they perform audits to evaluate - the implementation- of the Philadelphia Electric Qualicy ' Assurance ' Prcgram.

D.2.2.5 IAo$11 cation of the ality Assurance Progr,am_

' The Quality Assuran'ce program has been er at ' v3 co include the following r  ; systems' and/or . items of activity.

? .. -

!s 7

l p,;.3 Sept. 1983 L. .,

>3-w-

9:,

2830602320 tGs ws: 2

.A . D.3 - PHILADELPHIA ELECTRIC CCMPANY OUALITY ASSURANCE PRCC RAj!

Q

-The-Philadelphia Electric quality assurance program has been developed '

with the 18 Criteria of '10CFR50, Appendix B (hereinaf ter ref erred to as NRC QA criteria)< as its basis ' It provides a systematic, controlled

- method of applying these NRC QA Criteria at all levels of the Limerick.

project' and ' establishes a means of f ollow-up and evaluation to ensure .

that the intent of ' these criteria are ac tually.me t.

More'specifically, Philadelphia: Elec tric requires of its contractors, Genera 1sElectric-NE30 ~and .Bechtel Corporation, that they =ee t the.

provisions of the' NIC criteria and that the applicable requirements bc invoked upon their Venders. inie plant constructor and sita subcontractors are required1 to meet the'same type of quality centrol provisions. This is accomplished as follows:

i a. . Quality control provisions are specifically applied to first

. level vendors, through a generic quality assurance-specification (Bechtel Corporation) or specific quality control plans (General Electric) coupled with provisions of applicable specifications, drawings, and purchase documents.- The contractors will designate the essential equipment- depending upon such considerations as the safety related function to be performed, its taportance to the overall system, and whether it- is deplicated in redundant -

ins talla tion. ' Appropriate NRC criteria will be applied to ,-

each component. -

O' n '

- b. The quality control requirements to be placed on key vendors,

~ _-

4

'I

" the constructor, and selected site subcontractors will be reviewed by Philadelphia Electric.

!L c. The quality control capability of potential vendors will be evaluated by General Electric-NE30 and Bechtel. .

d. The Philadelphia Electric three level quality assurance progrcm

- identifies a clear line of responsibility for implementing -

quality ~ requirements and provides a means f or ensuring that the quality requirements specified are being met.. This, the (

' first level vendors, the constructor, and the site. subcontractors t

f, are required to have. chair own-inspection and quality control

' efforts to assure that specifications and other requirement '

documents are met. The second level' quality assurance audit or survoillance functions purformed by General Electric-NEB 0 l and Bechtel provides .a means for ensuring the work carried out

f. by the vendors, constructor, and subcontractors meet specified i

' requirements. Finally, the third level PhiladcIphia Electric- '

i.'

' quality assurance uf fort provides a separate and independent monitoring 'of the overall-QA progran to ensure that it is L

functioning as planned.

-e.. Pertinent inspection, quality control, and quality assurance documentation will be maintained f or this project.

L: (*~Yv_

D.3-1 Sept. 1983 l

f e- 44s.,, - , . _ w-----, _. ,m_ w- .,,, ,,-m_, .-+ , ,,e,,-.,c., . . . . -.--.mx_v9,_,--y- ._,.,.,w ,.,,g-yy,,- --...,,,my-,m,,.,,, -,,p,yp_,,. py-a,yy 7%..,,w-s.-

- ~

28 0602320 1.cs

' M.' &

n General Electric-NE30 and Bechtel will maintain the specified quality control

p. A ' rueurds suppiled by chuir vendurs f or the equipment they prepare (e< cept for such

.A records : hat code requiremen:s specify the~ vendor must retain) . I: is planned

hat' :hese records be turned over to Philadelphia Electric.

Per:inent audit- and su rveillance inspection reports, 'and tha documentation of design reviews will be main:ained by General Elec:ric NE30 and 3ech:e1 acccrding .

to writ:en provisions in their quali:y control plans.

Bech:el .will documen: site work according to specific requirements contained

- -1:i' applicable specificacions and field quali:y control procedures.- Thes e records will be compiled and turned over to philadelphia Electric at the comple tion of the project construction.

Philadelphia Electric will document audits and reviews of. specifications, drawings and other technical' requirements.

~

The vendor s' hall 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 qualifications governing subsections D.4.1 thrcugh D.4.13 fcr reviaw by General Electric or Beclitcl .( as appropria tu) . If concurrunce with these documents is required by the purchase crder, the vendor shall.not start work en a specific task governed by a procedure until the procedure has been reviewed and comments

', ' resolved satisfactorily.

Manufacturing processing, testing, and inspection operations performed by

.' vendors and their subcontractors shall be subject to quali:y audi: or

' surveillance with respect to the contract work by General Elec tric or Bechtel, as - sppropriate. Philadelphia Elec tric and/or its agent, working

- through General Electric or Bechtel, shall be accorded ' access f or audit or wi tnes s pur,.oses . - In this regard, any quality audit or surveillance by General Electric, Bechtcl, 'or Philadelphia Electric and/or its agent shall

- i not relieve the vendor or subcontractor of any responsibility f or meeting contract requirements.

t

.D. 4 ~. 15 - Audit of the OA Program Surveillance and auditing by the second and third level groups on the firs t level-will be used _ to assure that the vendors are complying with specifications, including the NRC QA cri:eria as invoked in the order.

i i -

The following is 3echtel's procedure for assuring that vendors are following the NRC QA criteria :

s -

i ~

a. Project Engineering prepares specifications and procurement documents

( calling the vsndor what technical requirements have to be met and I

reques:ing that the vendor describe his QA program showing how he will satisfy the~ NRC QA criteria.

E D.L-h Sept. 1953 i

E.

l

~

2830602320

. HEY' L 7-s b. Projec: En;inescing reviews the vendor's pregra= to see tha: 1:

U. satisf ac:orily =ee ts :he NRC QA criteria and technical require =en:s s,+

. :as se: f or th in the specifications,

e. ..c retiua rc=cn:s of tha vendar's QA pro;;ra= are included in the con:rac:ual d:cu=2n:s and once :he con:rac: is awarded, the vendor accepts respcasiolli:y to assure contractual cc:=:1:=en:s are =et including the ' applicable NRC QA criteria and technical require =en:s.

d. To. assure the vendor's shop prac: ices are =ee:ing :he applicable NRC QA criteria and technical require =en:s,3echtel Procure =ent provides surveillance of :he vendors' shops.

The f clicwing. is General Elec:ric's procedure for assuring that vendors are -

sa:isfying the intent of. the NRC QA criteria:

a '. General Elec:ric, previcusly and currently, has been applying appropriate QC plans on vendor supplied equip =ent. These QC plans embody- the appropriate require =ents of the NRC QA criteria.

~;..

b. General Electric will provide an audit or. surveillance function of. its

+

vendors ' work to assure that the specified quality require =ents are =et .

c. Design control ac:ivitics are docu=ented in formal General Electric docu=ent sysce=s tha: require vendor co=pliance wi:h design cri:eria and sub=1:tal of designs, specifications, and designated vendor procedures to General Elec:ric for review and approval.

8.] -

1 Philadelphia Electric-audits on a spot check basis the General Electric SE30 and.

. Bechtel efforts to ensure vender co=pliance with the in:en: of the :RC QA cri:eria and si=ilarly audits selected vendors.

t J

4 r

(O4j. _

D.1;-3 Sep:. I983 i

~ ,-y,g - . , , - , , - ,w- n- -s,. ,.,--,y , . , . , --- ,y-, ,,,-,,,..,,----y,y.o,v, ,,nn,.----,,,---y .,