ML20134M110
| ML20134M110 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 11/14/1996 |
| From: | Kropp W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Myers L CENTERIOR ENERGY |
| References | |
| NUDOCS 9611220222 | |
| Download: ML20134M110 (2) | |
Text
,.
1 November 14, 1996 Mr. Lew W. Myers Vice President - Nuclear Centerior Service Company P.O. Box 97, A200 U
Perry, OH 44081
Dear Mr. Myers:
i Thank you for your 10 CFR 50.54(a) submittals dated July 23 (letter PY CEl/NRR-2079L)
{'
and November 12,1996, which proposed changes to your Quality Assurance Program j
description. The November 12 submittal provided additionalinformation and modifications I
to the July 23 submittal. Your submittals proposed an organization change in which the
{
primary responsibility for overseeing the quality assurance program would be transferred to j
the Manager, Quality Assurance Section (QAS). Our understanding is that qualification requirements described in these submittals supersede those described in your 3
5 10 CFR 50.54(a) submittals dated July 23 (letter PY-CEl/NRR-2078L) and August 8,1996, l
which had been approved by the NRC on August 9,1996. This understanding was discussed between Mr. Emley of your staff and Mr. Ronald A. Langstaff of the NRC on November 13,1996. We have reviewed the changes associated with these submittals.
Based on our review of your submittals, we conclude that this revision continues to meet
}
the requirements of 10 CFR Part 50, Appendix B, and is acceptable.
We appreciate your timely submittal of information required by 10 CFR 50.54(a). If there are changes to quality assurance commitments existing in docketed correspondence outside of the Quality Assurance Program description, you are obligated to notify this
-office. Please contact Mr. Langstaff of my staff at (630) 829-9747 with any questions you may have regarding this matter.
Sincerely, l
Original signed by Andrew Dunlop for Wayne J. Kropp, Chief Engineering Specialists 1 Docket No. 50-440
Enclosures:
1.
CEI itr PY-CEl/NRR-2079L fm Shelton to NRC dtd 07/23/96 2.
CEI ltr PY-CEl/NRR-2115L fm Myers to NRC dtd 11/12/96 See Attached Distribution DOCUMENT NAME: G:\\DRS\\PER111_6.DRS To receive a copy of thle document, indicate in the box *C" = Copy without attach /enci *E* = Copy with attach /enct *N* = No copy OFFICE Rlli C-Rlli C
Rlll Y
/
RLangstaff:nN WKrdh,pjn JJacobson NAME DATE 11/f(/96 11//T/96 11//'//96 OFFICIAL RECORD COPY 4
a<
'hJ 9611220222 961114 PDR ADOCK 05000440 DEN 1
H PDR
1
^
L. W. Myers 2 l
cc w/encls:
J. P. Stetz, Senior Vice i
President - Nuclear i
L. W. Worley, Director, Nuclear i
Services Department J. D. Kloosterman, Manager, Regulatory Affairs W. R. Kanda, Director, Perry Nuclear Assurance Department N. L. Bonner, Director, Perry Nuclear Engineering Department H. Ray Caldwell, General Superintendent l
Nuclear Operations R. D. Brandt, General Manager Operations Terry L. Lodge, Esq.
State Liaison Officer, State of Ohio i
Robert E. Owen, Ohio Department of Health C. A. Glazer, State of Ohio i
Public Utilities Commission Distribution:
Docket File w/encls DRS w/encls A. B. Beach, Rlli w/encls PUBLIC IE-01 w/encls Rlll PRR w/encls Enf. Coordinator, Rlll w/encls OC/LFDCB w/encls SRI, Perry w/encls CAA1 (E-mail) w/encls DRP w/encls LPM, NRR w/encls W. L. Axelson, Rlli w/encls R. A. Gramm, NRR w/encls
O CENTERIRR v
ENERGY PERRY NUCLEAR POWER PLANT Mad Address' Donald C. SheltOn to CENTER ROAD RR O 10 44081 SENIOR VICE PRESIDENT PERRY, OHIO 44081 (216) 259-3737 NUCLEAR 1
j July 23, 1996 PY-CEI/NRR-2079L United States Nuclear Regulatory Commission i
Document Control Desk Washington, D.C.
20555 Perry Nuclear Power Plant Docket No. 50-440 10CFR50. 54 (a) (3)
Organization Change for the Perry Nuclear Assurance Department and the Perry Training Section Gentlemen:
The Perry Nuclear Power Plant (PNPP) is planning an organization change involving nuclear training and quality assurance.
The change is being pursued as part of PNPP's overall efforts to streamline the organization and realign groups to improve communications, work flow, and effectiveness.
Under the planned change, the Perry Training Section will be transferred from the Perry Nuclear Services Depaiatment to the Perry Nuclear Assurance Department (PNAD).
In conjunction with PNAD accepting the training responsibilities, some Nuclear Quality Assurance Program responsibilities will be transferred from the Director, PNAD to the Manager, Quality Assurance Section (QAS). A listing of the transferred responsibilities is contained in Attachment 1.
In conjunction with the increased Quality Assurance Program responsibilities, the Manager, QAS will have the authority to directly access the Vice-President, Nuclear - Perry for quality issues.
The Director, PNAD will retain the responsibilities involved with the administration and management of the Quality Assurance, Quality Control, Independent Safety Engineering Group (ISEG), Perry Training, and Quality Services sections. This responsibility alignment will enable PNAD management to have the organizational freedom, independence, and sufficient authority to fulfill the Nuclear Quality Assurance Program responsibilities and, at the same time, accept the nuclear training functions.
..j 960729003kM 3
PDR ADDC 05000440 H
pop iM, Operating Companies Cleveland Electne muminoimg Toseco Edison
e l
PY-CEI/NRR-2079L.
July 23, 1996 Page 2 of 2 Review of.this change is being requested pursuant to the provisions of 10CFR50.54 (a) (3),- as it is considered to reduce the commitments in the Quality Assurance Program description previously accepted by'the NRC.
The change reduces the_ current commitment for the Director, PNAD to have no other duties or responsibilities unrelated to Quality Assurance,.
Quality Control,.ISEG, and Quality Services.
Effects of-the commitment.
reduction'are minimal because successful performance and management of-quality assurance functions will not be impaired. The der. ails and bases for the change are contained in Attachments 2 and 3.
If you have questions or require additional information, please contact Mr. James D. Kloosterman, Manager - Regulatory Affairs at (216) 280-5833.
.Very tru
- yours, i
JFP:JEE:sc Attachments cc: NRC Region III Administrator NRC Resident Inspector-NRC Project Manager
PY-CEI/NRR-2079L Page 1 of 5 r
TRANSFER OF RESPONSIBILITIES AND DUTIES FROM THE DIRECTOR, PERRY NUCLEAR ASSURANCE DEPARTMENT TO THE MANAGER, QUALITY ASSURANCE SECTION DIR = Director, Perry Nuclear Assurance Department (PNAD)
MGR = Manager, Quality Assurance Section (QAS)
CURRENT PROPOSED USAR REF.
RESPONSIBILITY DIR MGR 17.2.1.3.2.2 Direct access to management levels to address quality issues.
Even though the Manager, QAS reports to the Director, PNAD, he will have direct access to the Vice President, Nuclear - Perry for issues involving quality assurance. This will ensure sufficient organizational freedom to ensure conformance to the Quality Assurance Program.
DIR MGR 17.2.1.3.2.2 Overall responsibility for verifying effective implementation of the Quality Assurance Program.
The Director, PNAP will retain overall responsibility fer the Quality Assurance Program since this includes the duties of the the Quality control Section. The Manager, QAS will assume responsibility for program implementation and effectiveness to avert any potential conflict of interest.
DIR MGR 17.2.1.3.2.2 IIas no other duties unrelated to QA.
The Director, PNAD will be assuming more responsibilities unrelated to quality assurance (i.e. the Perry Training Program).
Therefore, the Manager, QAS is being designated as the individual that will be able to give full attention to quality assurance matters.
DIR MGR 17.2.1.3.2.2 Provide for a system of planned and periodic internal audits to assure the implementation of QA policies, procedures and instructions addressed in the Operational QA Program.
The Manager, QAS will be responsible for the internal audit program so that he can fulfill his responsibility for verification of Quality Assurance Program implementation.
PY-CEI/NRR-2079L Page 2 of 5 DIR MGR 17.2.1.3.2.2 Regularly report to the Vice President, Nuclear - Perry, the status of quality activities, and bring to his attention, immediately, any significant quality-related problem or deficiency.
This responsibility will be assumed by the Manager, QAS so that quality issues may be presented to upper management if needed.
DIR MGR 17.2.1.3.2.2 Periodically evaluate and report on the status and adequacy of the Quality Assurance Program to appropriate management.
This responsibility is being transferred as part of the Manager, QAS responsibility for verification of effective implementation of the Quality Assurance Program.
DIR MGR 17.2.1.3.2.2 Initiating stop work, or control further processing, delivery, or installation of nonconforming material or activity as described in applicable quality assurance procedures and instructions and in the applicable plant procedures and instructicns.
The Manager, QAS will assume this responsibility as the quality assurance individual who has sufficient organizational freedom to verify effective implementation of the Quality Assurance Program.
DIR MGR 17.2.1.3.2.2 Qualification requirements for the Manager QAS at the time...
These qualification requirements, which were previously prescribed for the Director, PNAD are to be applied to the Manager, QAS since he is the individual responsible for ensuring effective implementation of the Quality Assurance Program.
DIR MGR 17.2.1.3.2.2.1 Overall responsibility for verifying the effective implementation of the Quality Assurance Program.
The Manager, QAS will assume overall responsibility for verification of quality activities.
PY-CEI/NRR-2079L Page 3 of 5 DIR MGR 17.2.2.3.2 As the official given direct responsibility for verifying...
j The Manager, QAS will assume responsibility for evaluating the adequacy and effectiveness j
of the Quality Assurance Program.
This includes assuring that appropriate corrective action is taken in a timely manner.
DIR MGR 17.2.6.3 Responsible for evaluation of the project document control effectiveness through audit and other QA techniques.
The Manager, QAS will be responsible for verifying implementation of document control measures as part of his overall responsibility for verifying effective implementation of the Quality Assurance Program.
DIR MGR 17.2.7.3 Responsible for assuring through audit, inspection, source surveillance, and program evaluation techniques, that the control of purchased equipment, material and services is established, approved, implemented, and effective.
The Manager, QAS will be responsible for verifying implementation of controls for purchased items and services as part of his overall responsibility for verifying effective implementation of the Quality Assurance Program.
DIR MGR 17.2.10.3 Verify through audit or other quality assurance management techniques, that inspection programs are effectively implemented.
The Manager, QAS will be responsible for verifying implementation of inspection programs as part of his overall responsibility for verifying effective implementation of the Quality Assurance Program.
DIR MGR 17.2.11.3 Verify the implementation of test control requirements through audits.
l
o e
PY-CEI/NRR-2079L Page 4 of 5 The Manager, QAS will be responsible for verifying implementation of test control measures as part of his overall responsibility for verifying effective implementation of the Quality Assurance Program.
DIR MGR 17.2.13.3 Verify the implementation of handling, storage and shipping requirements.
The Manager, QAS will be responsible for verifying implementation of handling, storage and shipping requirements as part of his overall responsibility for verifying i
effective implementation of the Quality Assurance Program.
DIR MGR 17.2.14.3 Through audits and the review of plant administrative control procedures shall verify the adequate establishment of programs for inspection, test and operating status both at the plant and in the facilities of vendors and contractors as appropriate.
The Manager, QAS will be responsible for verifying implementation of inspection, test and operating status programs as part of his overall responsibility for verifying effective implementation of the Quality Assurance Program.
DIR MGR 17.2.15.3 Verify the adequate implementation of nonconformance control both at the plant and in the facilities of vendors and contractors.
The Manager, QAS will be responsible for verifying implementation of nonconformance control measures as part of his overall responsibility for verifying effective implementation of the Quality Assurance Program.
DIR MGR 17.2.16.3 Resolving corrective action impasses with corporate management and delegating stop work authority to PNAD personnel and agents.
The Manager, QAS will be responsible ensuring corrective action is taken and for stopping work, when appropriate, as part of his overall responsibility for verifying effective implementation of the Quality Assurance Program.
a PY-CEI/NRR-2079L Page 5 of 5 DIR MGR 17.2.17.3 Performing planned and periodic audits to verify adequacy and implementation of QA record requirements by both internal organizations and external suppliers.
The Manager, QAS will be responsible for i
verifying implementation of record control measures as part of his overall responsibility for verifying effective implementation of the Quality Assurance i
Program.
DIR MGR 17.2.18.3 Providing a system of planned and periodic audits of organizations performing safety-related activities..
The quality assurance audit program will become the responsibility of the Manager, QAS as part of his overall responsibility for verifying effective implementation of the Quality Assurance Program.
f
1 PY-CEI/NRR-2079L Page 1 of 3 Summary of the Proposed Chance The Perry Training Section will be transferred from the Perry Nuclear Services Department to the Perry Nuclear Assurance Department (PNAD).
The transfer of training functions to PNAD represents a reduction in Quality Assurance Program commitment because the assignment conflicts with the commitment for the Director, PNAD to have no other duties or responsibilities unrelated to Quality Assurance, Quality control, Independent Safety Engineering Group (ISEG), and Quality Services. Addition of the training responsibilities could dilute the ability of the Director, PNAD to give adequate attention to Quality Assurance, Quality Control, ISEG, and Quality Service matters as intended by USAR 17.2.1.3.2.2.
Therefore, in order for PNAD to accept the training responsibilities, the change will transfer some of the Nuclear Quality Assurance Program responsibilities from the Director, PNAD to the Manager,-Quality Assurance Section (QAS).
Details of the Proposed Chance Numerous text changes to the Perry Nuclear Power Plant (PNPP) Updated Safety Analysis Report (USAR) Chapter 13.1, " Organizational Structure of Applicant" and i
Chapter 17.2, " Quality Assurance During the Operations Phase" are being made to i
incorporate the transfer of training to PNAD and modification of Director, PNAD responsibilities, The changes can be summarized as follows:
i 1.
The Perry Training Section (PTS) will be transferred from the Perry Nuclear Services Department to the Perry Nuclear Assurance Department.
The Manager, PTS will report to the Director, PNAD.
2.
Responsibilities of the Director, PNAD have been categorized into either line-management, or Quality Assurance Program and assessment activities.
The Director, PNAD retains management responsibilities for managing the Quality Assurance, Quality Control, ISEG, Perry Training, and Quality Services sections. The Quality Assurance Program and assessment responsibilities will be assigned to the Manager, Quality Assurance Section.
3.
The Manager, QAS is assigned overall responsibility for verifying the effective implementation of the PNPP Nuclear Quality Assurance Program.
Specific responsibilities include:
j
{
- review of the Quality Assurance Program to ensure it meets standards, regulatory commitments, and the Quality Assurance Program description,
- stop work authority, t
- review and approval of procurement documents,
- supplier evaluation and control,
- assuring proper control of purchased material, equipment, and services, i
I
.~
.. - -~
o 1
PY-CEI/NRR-2079L Page 2 of 3 l
conducting planned, periodic internal audits and surveillances to assure proper implementation of-the Quality Assurance Program,'
- regularly reporting to the Vice President, Nuclear - Perry the status of quality activities,
- periodic evaluation and reporting on the status and adequacy of the Quality Assurance Program,
- resolving corrective action impasses with plant management, and
- verifying that controls / programs for inspection, records, nonconformances, test control, document control, inspection, test and operating status, and handling, storage, and shipping are effectively implemented The Manager, QAS will maintain a line reporting relationship to the 4.
Director, PNAD.
For quality and assessment issues, the Manager, QAS will j
have direct access to the Vice President, Nuclear - Perry.
Specific details of the changes are shown on the marked-up USAR pages provided in Attachment 3.
Note, several of the marked-up pages have other USAR changes posted against them which are not relevant to this proposed change.
For ease of understanding, the marked-up pages provided will only reflect this proposed change.
j Basis for the ProDosed Chance Under the proposed organization and responsibility changes, the PNPP Nuclear Quality Assurance Program will continue to implement the quality assurance I
functions described in 10CFR50 Appendix B Criteria 1,
" Organization". These functions include:
Assuring that an appropriate Quality Assurance Program is established and a.
effectively executed, and b.
Verifying, such as by checking and auditing, that activities affecting the safety-related functions have been correctly performed.
The Manager, Quality Assurance Section will assume the authority and responsibility for these quality assurance functions. To effectively implement these functions, the Manager, QAS will be given, through the Nuclear Quality Assurance Program Policy, the required authority and organizational freedom.
The Manager, QAS will have sufficient independence from cost and schedule to execute the quality assurance functions involving safety considerations. The Manager, QAS will be free from non-QA related duties.
The Manager, QAS will administratively report to the Director, PNAD while having direct access to corporate management up to and including the President, Chairman and Chief Executive Officer for quality matters if needed.
A listing of current and proposed quality assurance responsibility assignments is provided in Attachment 1 for easy comparison.
PY-CEI/NRR-2079L I
l Page 3 cf 3 i
The Director, PNAD will retain the responsibilities involved with leading and managing the Quality Assurance, Quality control, ISEG, Perry Training, and Quality Services sections. This responsibility alignment will enable PNAD management to provide full attention to QA and ISEG matters and have the organizational freedom, independence, and sufficient authority to fulfill the nuclear quality assurance program responsibilities and at the same time accept l
the nuclear training functions.
l s
e i
i l
i l
I PY-CEI/NRR-2079LL Page I of 30 i
13.1.2.2.3 Perry Nuclear Services Department i
Director, Perry Nuclear Services Department The'D'irector, Perry Nuclear Services Department (PNSD) has overall responsibility for the strategic and outage planning, centralized scheduling, developing and maintaining the overall Perry budget.
Additionally, this director has the overall responsibility for material services.::d training.
<2' Revision 7 13.1-18 March, 1995
~.
PY-CEI/NRR-2079L
~ Attachment 3 Page 2 of 30
]
This director is also responsible for compliance with the plant l
operating license, regulations, and the Operational Quality Assurance Program. The Director, PNSD reports to the Vice President, Nuclear -
i
'##7*
/
% () yt YO ll. S. li 'h,1. A. D
( poc < n.7-14) hn=ger. Parru 'Pr2fning-Sect 4 j
The Manager, Perry Training Section is responsible for developing a I
Perry Training Program based on the input and direction of the Perry departments. This manager is also responsible for overall maintenance j
and osieration of the control room simulator, selecting and certifying instructors, scheduling training activities and maintaining j
documentation of training completed. The Manager, Perry Training I
Section reports to the Director, 7;;50. C p/\\/ /} D, Manager, Work Management Section m
The Manager, Vork Management Section is responsible for directing the scheduling for maintenance and testing performed during power operations, planning the maintenance, repairs, overhauls, testing, and modifications of mechanical and electrical equipment during operations and forced outages. In addition, this manager is responsible for developing schedules which integrate the design engineering of projects with the planned installation schedules. The Manager, Work Management Section reports to the Director, 'PNSD.
1 Revision 7 13.1-18a March, 1995
-. ~_-._-. -.
PY-CEI/NRR-2079L a
Page 3 of 30 i
i i
J l
4 1
Manager, Materials Management Section The Manager, Materials Management Section is responsible for planning 1
for material requirements; maintaining and monitoring inventory levels; l
coordinating the procurement, receipt and issuance of materials; and coordinating storage to meet maintenance requirements. The Manager, Materials Management Section, reports to the Director PNSD.
13.1.2.2.4 Perry Nuclear Assurance Department (PNAD)
)
The Perry Nuclear Assurance Department has the functional authority, independence, and responsibility to verify the effective implementation of the administrative controls and the Quality Assurance Program during n
the Operational Phase of Per p. The Director, PNAD reports directly to the Vice P dent, Nuclear - Perry. Thi eporting relationship has been blished to vide PNAD vi sufficient independ from the influence of co and schedule o be able to effect y assure conforman to Operation ualit'y Assurance gram requir nts. The MNO Dir or, PNAD, has e overall author and responsi ity for the Quality Assur e Program for Pe The Direct
, PNAD als.o.ha e
overall r, ponsibility for oviding gener and procedura administrative services, document control, and records management.
Refer to SectionM1.3.2.2 for additional information regarding the Perry Nuclear Assurance Department.
Revision 7 13.1-19a March, 1995
PY-CEI/NRR-2079L Page 4 of 30 j
TABLE 13.1-1 PERRY STAFF TITLES AND ANSI N18.1-1971 EQUIVALENT Perry Position or Title ANSI N18.1-1971 Equivalent General Manager, Perzy Nuclear
- Plant Manager Power Plant Department i
Dift.Cicf, fu nl w m\\tu r Tecknka) n%na0 er Nuc a ssean ct D go ent-Director, Perry Nuclear Services Dept.
Technical Manager Director, Perry Nuclear Engineering
- Engineer In Charge Dept.
- Technical Manager j
Manager, Perry Operations Section
- 0perations Manager Supervisor, Radwaste Unit
- Supervisor not requiring NRC License Superintendent, Plant Operations Operations Manager Shift Supervisors
.O
- Supervisors requiring NRC s/
License Unit Supervisors
- Supervisors requiring NRC License SupervisingOperators\\
- 0perators i
Manager, Perry Maintenance Section
- Maintenance Manager Lead Supervisor, Maintenance Unit
- Supervisor not requiring NRC License Supervisors, Maintenance Supervisors not requiring NRC License Manager, Materials Management Section Maintenance Manager Lead Instrumentation and Control Instrumentation and Control Engineer
- Professional-Technical Lead Instrumentation and Control
- Supervisor not requiring NRC Supervisor License Revision 7 13.1-26 March, 1995
O 8
PY-CE1/NRR-2079L REGULATORY AFFAIRS MANAGER RADIATION Pf;OTECTION l
MANAGER TEh?Y OPERATIONS l
PERRY NUCLEAR POWER A R I
PLANT DEPARTMENT GENERAL MANAGER PERRY MAINTENANCE g
MANAGER SITE PROTECTION l
MANAGER l
l MECHANICAL DESIGN g
MANAGER l
CIIAIRMAN, ELECTRICAL DESIGN g
MANAGER PRESIDENT, PERRY NUCLEAR CEO ENGINEERING DEPT.
DIRECIOR ENGINEERING g
SUPPORTMANAGER I'
SYSTEMS ENGINEERING l
MANAGER SENIOR l
VICE PRESIDENT NUCLEAR INDEPENDENT SAFETY g
ENGINEERING GROUP MANAGER VICE PRESIDENT l
QUALTPY CONTROL PERRY NUCLEAR MANAGER NUCLEAR PERRY l
ASSURANCE DEPARTMENT-R t- - - _ _ _ l 4
QUALTIY ASSURANCE Z
MANAGER p.
l QUALITY SERVICES MANAGER l
PEmf T RAWW 6 M ANAG6R VICE PRESIDENT l
FINANCE AND g
OUTAGE, PROJECIS.
ADMINISTRATION AND COST CONTROL l
MANAGER I
l, hM&
PERRY NUCLEAR PROCUREMENT NUCLEAR
_,1,_, SERVIC RTMENT DEPARTMENT PURCHASING l
MANAGER I
MATEMAM MANAGFMENT HOME.
SITE l
MANAGER OFFICE OFFICE l
CEI l
I I
CENTERIOR (Rev. 7 3/95) g ON PERRY HUCLEAR POWER PLANT THE CLEVELAND ELECTRIC ILLUMtHATlHG COMPANY Perry Power Plant Operat2ng Organization Figure 13.1-2
-. = _ _ =
. - _ -. ~...
PY-CEI/NRR-2079L Page 6 of 30 4
i a
a PERRY NUCLEAR i
SERVICES DEPARTMENT DIRECTOR I
/
/
\\
WORK MANAGEMENT MATERIALS sECTION OUTAGE, PRCLIECT5
/
6 PERRY TRAL.
MANAGEMENT MANAGER AND COST CONTROL sECTION MANAGER MANAGER
~
a sm
/
sm sm
/.
sm /
4 1
Wdo 4
d t
(Rev. 7 3/95) e PERRY NUCLEAR POWER PLANT THE CLEVELAND ELECTRIC ILLUMINATING COMPANY Perry Nuclear Services 4
Department Organization 4
Figure 13.1-5
PY-CEI/NRR-2079L Page 7 of 30 Responsibility for review and coordination of their activities rests with the Director, PIED. The Director, PIED, is the Chairman of the Plant Operations Review Committee.
1 hVEL-The Perry Nuclear Services Department consists of sections: Work j
Management, Outage, Projects,andCostControl,MaterialsManagementj er.d Perrj t aining Sections. The responsibili ies of each element are-o discussed in Section 13.1.2.2.3.
OmJ
)
l l
fiv4_
'Ite Perry Nuclear Assurance Department consists of [
sections: Quality Assurance, Quality Control, Quality Services,-amp 2.--
Independent Safety Engineering Group Sections. The responsibilities of the department and each section are discussed in Sections 17.2.1.3.2.2, 17.2.1.3.2.2.1, 17.2.1.3.2.2.2, 17.2.1.3.2.2.3, 17.2.1.3.2.2.4J l
dwcf17.2.I,3,0.,A,E, GAAd E U s[ [ ( U ) % )V\\ O l
t
\\
~
l Revision 7 i
17.2-6 March, 1995
PY-CEI/NRR-2079L Page 8 of 30 bshitA Y \\l, 1N N @ M} V, 0dQ bl033LifdM2.
kdlM (QOS),bd3c((reGiG.CCe5$30 k ke. Pres 1clevtf, Alu dear - haq For prEty USueS, n
h
.I
\\
17.2.1.3.2.2 Perry Nuclear Assurance Department (PN D)
The Perry Nuclear Assurance Department has the function authority, independence, and responsibility to verify the effectiv implementation of the administrative c,ontrols and the Quality Assuran e Program during the Operational Phase of the Perry. Designated PNIO dividuals routinely attend plant work schedule and status meet s in order to identify those plant activities which are safety-re ted and require OA coverage so that appropriate OA 9,bntrols may be ap ied. Figure 17.2-2 shows the organizational structure of PNAD. The rector, PNAD reports U oirecdy-to the Vice President, Nuclear - Perry. This reporting relationsh'ip'has bebn established to provide ith sufficient independence from the influence of cost and Tb4-[ddHQg4f, hk Revision 3 17.2-9 March, 1991
--- - _. - =-
PY-CEI/NRR-2079L i
Page 9 of 30
]
1 schedule to be able to effectively assure conformance to Operational Quality Assurance Program requirements. The Director, PNAD, has the i
overall authority and responsibility for the Quality Assurance Program for Perry.
1 h C-D H Qj ef, & A S, hD.$ 0 J era)] f CQCDU b El1 t Y Ur V R d [y 1k e Wed ivo h fem en $Qflh C hL NJ0 ht $$Qfa /$
M M mctor, r!!!O, has no other duties or responsibilities unrelated to afb i
l o
of"
{
OA,end -IS"C, except for-those-1 ton-quam 4y--assurance-related Iunct Dthe M= ger, ^;;11ty Scrficer Sect -v Therefore, the
[eN[II r:JI L i
vill be able to give adequate attention to OA w.d I [ matters. T;.e ;-
Di..cter, ri:.'s has direct acca: te ---- :::nt 1: cls which vill assure 9
% j= ="-- 'ry; ni,has a staff ofssufficient size which will assure the ability: f
]
nla. D >.<edor, PNA D, a.
To evaluate the manner in which all activities, both onsite and offsite are conducted, with respect to. quality, by means of check, review, audit, surveillance, and inspection.
1 b.
To perform evaluations on a planned and periodic basis to verify that the Quality Assurance Prograa is being effectively implemented.
c.
To identify quality problems, to initiate, recommend or provide solutions through designated channels and to verify implementation of resolutions.
.i d.
To initiate stop work action or control further processing, 4
delivery, or installation of nonconforaing material or activity as described in the applicable quality assurance procedures and instructions and in the applicable plant procedures and instructions.
~
Revision 7 17.2-10 March, 1995
= _ - - -. -. - _ =.. - _.
i i
PY-CEI/NRR-2079L Page 10 of 30 i
The specific responsibilities of the Director, PNAD, include the following:
Prepare, review and approve procedures and changes thereto, a.
required to implement the requirements of this OA Program.
t s
TB\\S PAG 6.15 l^l cLuoED F 08. \\ N FO RmhTION.
L (
~
l
/V O Cl4 AN G66 O N T1413 PA CrE i
l i
i l
l l
l 1
Revision 7 17.2-10a March, 1995 I
l
I PY-CEI/NRR-2079L Page il of 30 b.
Provide for the review and approval of the OA program of contractors providing services, and of vendors supplying materials, parts or components covered by the scope of this document.
l Provide for review and approval of procedures prepared by other c.
organizations when these procedures control or exercise an effect upon an activity that falls within the scope of this document.
d.
i Provide direction and supervision of the PNAD organization.
Maintain a working interface and communication with the NRC, other e.
organizations, consultants,' contractors, vendors, and others as required to effectively execute the policies presented in this description of the OA Program.
f.
Provide for a system of planned and periodic audit and inspection of organizations, contractors and vendors performing activities that fall within the scope of this document.
I.
ovide for system lanned periodi ternal audit to g
)
assur he impl ntation OA polici
, proced s and l
i l
structi by orga ations ad essed in e Operat nal OA Progr j
Establish and assure the continuous implementation of an indoctrination and training program for PNAD OA/0C personnel and assure that a quality assurance indoctrination is provided to appropriate personnel outside the OA organization.
i.
ularly r ort to th ce Presi t, Nuclea - Perry, t st t / of qua y activ es, and br g to his ention i latel, any si ificant qtfality-rela problem deficien
/
Revision 3 17.2-11 March, 1991
PY-CEI/NRR-2079L Page 12 of 30 h J.
Proviae for OA review and concurrence of safety-related plant modification and maintenance work authorizations. This includes l
the review of associated design documents to ensure proper review i
and' approval, and inclusion of necessary quality assurance requirements.
j j.
Provide for OA review and appmval of procurement documents i
generated for the acquisition of materials and services that fall within the scope of this document.
j.
Provide for and maintain Quality Assurance records generated by PNAD until such time as they are turned over for permanent storage.
[ Pe ica N yaluat d repo d n the atus d ad acy of
./Quali[Assur
[j Progr o appro ate agen k
j.
Perform receiving inspection activities at the plant site.
J, ' ).
Provide for adequate levels of inspection and surveillance of plant activities.
fy) j.
Provide the resources necessary to ensure that the Independent i
Safety Engineering Group can perform the activities described in Appendix 1A, Item I.B.l.2 and Section 13.4.3.
A, j.
Provide general and procedural administrative services, document control and records management.
D eV e.\\ o,f G.
dweda o r hj TraQ shg Ptyram bust 0 M gn fukadd Perrs c').
Pwq dqactmm fs.
2.; t 'y
( 'Oualification requirements for the Lucun, LC, ei are:
Uldh<2g er, @A%
! ggt /} {
a.
Management experience through progressive assignment of increasing responsibility.
4 b.
Formal degree in a science or engineering discipline or
~
professional registration or equivalent ExperienC4_.
Revision 7 17.2-12 March, 1995
PY-CEI/WRR-2079L Page 13 of 30 It1 SERT A The specific responsibilities of the Manager, QAS, include the following:
Provide for a system of planned and periodic internal audits to assure the a.
implementation of QA policies, procedures and instructions by organizations 4
addressed in the operational QA Program, b.
Regularly report to the Vice President, Nuclear - Perry, the status of quality activities, and bring to his attention bmmediately, any significant quality-related problem or deficiency.
Periodically evaluate and report on the status and adequacy of the Quality e.
Assurance Program to appropriate management.
d.
Initiating stop work, or control further processing, delivery, or installation of nonconforming material or activity as described in the applicable quality assurance procedures and instructions and in the applicable plant procedures and instructions, i
I i
I
" ~ " ~ ~
PY-CEI/NRR-2079L
}
Page 14 of 30 plant experience in the overall implementation of the Quality
)
i Assurance Program. A minimum of 1 year of this 6 years experience shall be related technical or academic training. A maximum of 4 years experience may be fulfilled by related technical or academic training.
d.
Training in OA policies, standards, regulations, and practices.
The Director, PNAD, is assisted in carrying out his
~
responsibilities by a staff organized into sections to provide adequate coverage of procurement, manufacturing, inservice
' inspection, refueling, maintbnance, repair, modification, and operation of Perry (Pigure 17.2-2).
The staff includes required expertise to perform audit, quality engineering, surveillance, and inspection functions.. In addition, quality assurance agents may be engaged to augment the PNAD staff. PNAD shall maintain direct control over any quality assurance agent.
i 17.2.1.3.2.2.1 Manager, Quality Assurance Section The Manager, Quality Assurance Section, is responsible for implementing asystemofplannedpebodicinternala ts and surveillances. Section activities include input to and review of procedures and' corrective action programs; reviewing changes to t Operatinns OA Plan; surveillance of plant operations;,shd oviding administrative support for PNAD.
17.2.1.3.2.2.9
.u...
r, Quality Control Section.
The Manager, Quality Control Section, is responsible for review and approval of procurement documents; maintains a program for approval, audit and surveillance of suppliers; and has awa)J Mspad sib: Uff Fx ve<; fy9 At effed &
% f tan a.El Y G 0lh GSSU/c4nct fm 9fG M.
NL A O l
Revision 3 17.2-13 March, 1991
o e
PY-CEI/NRR-2079L Page 15 of 30 performs receipt inspection for items and services within the scope of this document. The Hanager, Quality Control Section is also responsible for coordinating site quality functions associated with construction, reviewing vork. orders, non-destructive examination (NDE) support, inspecting maintenance or modification activities for Perry, reviewing vork procedures and completed documentation and providing PNAD coordination and support for outager during operations.
17.2.1.3.2.2.3 Hanager, Independent Safety Engineering Group The Manager, Independent Safety Engineering Group (ISEG) is responsible for performing the activities contained in the ISEG Charter as described in Appendix 1A Item I.B.1.2 and Sections 13.4.3.
This Manager ensures that the ISEG examines plant operating characteristics, NRC issuance, industry information and other sources of design and operating experience that may indicate vays of improving plant safety. The ISEG performs periodic, independent reviews of plant activities and aids in establishing programmatic requirements. Members of the ISEG report to the Manager, ISEG, who reports to the Director, PNAD.
17.2.1.3.2.2.4 Hanager, Quality Services Section The Manager, Quality Services Section is responsible for implementing the Perry procedure / instruction program, performing document and drawing control activities, providing permanent storage for and retrieval of construction and operations records, and for furnishing administrative services in support of plant activities. The Hanager, Quality Services Section reports to the Director, PNAD.
n, 'A. ),3, a. 2 X thanag eq Perr4 raimHg % fha T
=7 Tdst from p,
- 13. l - I B cc Revision 7 17.2-14 March, 1995
PY-CEI/NRR-2079L Page 16 of 30 4
l Any corrective action which may be deemed necessary, as a result of these year'ly assessments, shall be formally identified and tracked
(
to resolution.
Qu(d ihj (d %LVA M4 $ccINM (hdh
{
^
/T)q no g V, 17.2.2.3.2
- Directe_, ? ct ri !!uclcar f.: ur=c Dcpartscat (Pi!!.D) P j
InQ nQg Uj & A $)
The Oirectc, Pi!!", as the official given direct responsibility for verifying the effective implementation of the Perry Operational OA Program, shall establish and implement a formally documented and procedurally controlled program to evaluate and report to the Vice President, Nuclear - Perry on.the adequacy and continued effectiveness of the overall Perry 00A Program. Reports of audits performed by PNAD or their agents, and quality trend analysis vill provide the basis for l
this evaluation. Corrective action shall be implemented by responsible management, as deemed appropriate, when analysis reveals adverse quality trends. These actions may involve specific actions to provide compliance with the OA Program, and may include follow-up audits or i
revision to the 00A Program. Implementation and close-out of corrective actions shall be monitored by the Circ:ter, P!'.S,-to assure timely correction and compliance.
M4 M4g U Ohk j
17.2.2.3.3 Director / General Manager of Each Organization The Director / General Manager of each organization is-responsible for l
implementing training and indoctrination programs for their respective organizations which meet the requirements in Section 17.2.2.2., Item g.
17.2.2.4 Delegated Authorities j
Ouality assurance programs and implementing procedures for suppliers or l
contractors providing materials and services for Perry which are covered under the scope of this OA Program shall be subject to review and acceptance by PNAD prior to the commencement of any activity covered under the scope of this OA Program.
Procurement documents shall i
Revision 7 17.2-21 March, 1995 l
PY-CEl/NRR-2079L Page 17 of 30 17.2.6.3 Responsibilities and Authorities 17.2.6.3.1 Director, Perry Nuclear Assurance Department
{
4 The Director, PNAD, is responsible for controlling documents affecting l
the quality of safety-related structures, systems and components at the plant in accordance with administrative procedures which conform to the requirements of this section. This responsibility includes the control and distribution of procedures and instructions at Perry.
The Director, PNAD, is also responsible for assuring the reviev and l
approval of project documents defining the document control measures.
S Mrt:tu,.T!.:;hesponsible for evaluation of the wu aoourt.,
project document control effectiveness through audit and other QA techniques f I]* 0 s b. b. 0 N G H #f W) 0 VObl$ } bM WUd(L Y lLN1 16 tna napr> Q AS, c
17.2.7 CONTROL OF PURCHASED MATERIAL, EQU MENT AND SERVICES 17.2.7.1 Policy The procurement control of material, equipment and services during the operations phase shall be performed in accordance with written policies and procedures. Quality Assurance measures shall apply to the procurement of services and materials including spare parts, replacement Revision 7 17.2-34 March, 1995
= -.
o PY-CEI/NRR-2079L Page 18 of 30 Commercial grade i tems shall be subject to receipt inspection as delineated in 17.2.7.2.1.(d) to provide the necessary assurance that an acceptable item has been furnished.
Special quality verification l
)
requirements shall be considered when specific quality assurance controls appropriate for nuclear applications cannot be imposed in a practicable manner.
j 1
17.2.7.3 Responsibilities and Authorities I
17.2.7.3.1 Department General Managers and Directors Each departmelit general manager or director is responsible for the establishment of procedures to ensure the control of purchased equipment, material and services and'for the development and administration of the special service agreements with their agents and consultants.
17.2.7.3.2 Director, Perry Nuclear Assurance Department The d" ---" g V., 0 %
MQna
"""" is responsible for assuring through audit, inspection, source surveillance, and program evaluation techniques, that I
control of purchased equipment, material and services is established, approved, implemented, and effective.
k The Director, PNAD, reviews and' approves Perry procedures for the l
control of purchased equipment, material and services.
- n. s. n. 3. s %a g v, Q u cEty ksww M5 D
Revision 3 17.2-38 March, 1991
e
=
PY-CEI/NRR-2079L Page 19 of 30 17.2.10.3 Responsibilities and Authorities 17.2.10.3.1 Director, Perry Nuclear Assurance Department The Director, PNAD, is responsible for the establishment of inspection plans, procedures, instructions, and checklists h hrough audit or other quality assurance management technises, that inspectio programsareeffectivelyimplemented.[Theinspectioneffortsatthe plant shall include the performance of receipt inspection on material, parts and components received at the site.
The Director, PNAD, is ret - 1sible for reviewing maintenance and modification procedures and/or safety-related work requests to determine the necessary inspection requirements, establish inspection hold or vitness points, designate inspection personnel and to develop inspection instructions and/or checklists and methods of documenting inspection results.
C*S./C.3. S Mana Fj @U c fl1[ Ofl#4d E
N W 0 [- e r Q A 6,,5 d t 6 '[
/
j 17.2.11 TEST CONTROL 17.2.1 olicy The basic requirements for all organizations performing tests on safety-related structures, systems and components during startup and throughout all phases of operati'on shall be defined. The test program shall be identified, documented and accomplished in accordance with procedures that are written, approved and controlled. The I
preoperational testing (performed in accordance with Section 17.1) and startup testing (performed in accordance with Section 17.2) controls are described in Chapter 14.
Tests performed after modification, repair or replacement shall be in accordance with the original design and testing requirements or properly approved acceptable alternatives. The extent of testing shall be based on the complexity of the modification, Revision 3 17.2-45 March, 1991
PY-CEI/NRR-2079L Page 20 of 30 h.
Handatory hold or vitness points for inspection by PNAD, the Authorized Nuclear Inspector and/or other designated personnel.
4 i.
Provisions for control of jumpers, lif ted leads and jurisdictional or safety tags.
j.
Provisions for returning a system to normal configuration upon completion of the test.
Test results shall be documented, evaluated and their acceptability determined by a responsible indivjdual or group.
17.2.11.3 Responsibilities and Authorities 17.2.11.3.1 General Manager, PNPPD, and Director, PNED The General Manager, PNPPD, and Director, PNED, are responsible for l
conducting test and test control activities at the plant in accordance with approved vritten procedures which conform to the requirements of this section.
The general manager assumes responsibility for test control of each system when that system is accepted from NTS as ready for fuel loading and startup.
Startup testing shall be reviewed by the PORC and, if acceptable, a recommendation for approval shall be made to the General Manager, PNPPD, and Director, PNED.
l 17.2.11.3.2 Director, Perry Nuclear Assurance Department The Director, PNAD, is responsible for revieving and approving test control procedures and reviewing instructions for testing activities to be conducted at the plant.
f all-fur e:r verify the implementation of test control requirements through the conduct of
..ym...._
...u
~
audits. [
17i%.II,3.3 MCM 4g V; h BON
/
I
- _/ncmq<5 GA-Revision 6 17.2-47 March, 1994
PY-CEI/NRR-2079L Page 2I of 30 17.2.13.3.2 Director, Perry Nuclear Assurance Department l
i The Director, PNAD, is responsible for receipt inspection verification of.special handling and packaging maintenance during shipment, and conducting inspections ad ndiMo verify the implementation of handling, storage and shipping requirements.
(
y 17.2.14 INSPECTION, TEST AND OPERATING. STATUS 17.2.14.1 Policy
-A program shall be established to indicate the inspection, test and operating status of structures, systems and components covered under the scope of this document.
The status of safety-related structures, systems and components shall be controlled in accordance with approved procedures.
These procedures j
shall include the use of appropriate tags, markings, lists, logs, f
diagrams, or other suitable means, to assure that required inspections i
and tests are satisfactorily completed to prevent inadvertent bypassing of required inspections and tests and to prevent inadvertent operation.
17.2.14.2 Requirements An acceptable inspection, test a d operating status program shall include:
l j
a.
The identification of inspection, test and operating status of I
structurcs, systems and components.
I f
b.
Procedures which include controls for the application and removal
,l of inspection and velding stamps, and other status indicators such i
I as tags, markings, labels, and stamps.
)
( l ~). 0. I 3. 3. b t h a n n y (2 0 'i sl (A J 1 U r a u ct
(
1(ft #1 anogr, Q45, 3had yyi fy fJt im [ dew Ma(Q@C
,1f,f 3
h""g j "O > NoF *c4sk'pgg qu ir< m e fs,
(
17.2-52 March, 1991 n
PY-CEI/NRR-2079L Page 22 of 30 4
Established inspection and test requirements which shall not be c.
bypassed or have the sequence altered, except by a revision to the i
inspection or test procedure, or as detailed by approved project procedures / instructions.
1 d.
i Records on the installation or erection, and its inspections and
{
tests, which shall reflect the operating status of systems, structures and components.
Identifying and preventing the inadvertent use of nonconforming, e.
inoperative, or malfunctioning structures, systems or'ecmponents by documenting the condition and appropriately tagging the item (s).
17.2.14.3 Responsibilities and Authorities 17.2.14.3.1 General Manager, PNPPD; Director, PNED, and Director, PNSD The General Manager, PNPPD, Director, PNED, and Director, PNSD are l
responsible for mai.ntaining the test and operating status of plant safety-related structures, systems and components.
17.2.14.3.2 Director, Perry Nuclear Assurance Department The Director, PNAD, is responsible for maintaining the inspection status of plant safety-related structures, systems and components and for the identification and tagging, when applicable, of nonconforming items at the plant.MJ through review and approval of plant administrative D
Gontrol procedures [auditsgnd in:pectim the Director, P."t.D, shall verify the adequate establishment of programs for inspection, test and operating status both at the plant and in the facilities of vendors and (contractors as appropriate.
f 17.S,Id 3i3
@dh (G bUC A5,5 W G H U. b [ /
i
-ib. r%af er> Q AS
.)
Revision 6 17.2-53 Harch, 1994
s PY-CEI/NRR-2079L 1
Page 23 of 30 1
k nonconformances, and the timeliness and adequacy of the reporting and resolution of nonconformances. Significant results shall be reported to management for review and assessment.
17.2.15.3 Responsibilities and Authorities i
17.2.15.3.1 General Manager, PNPPD; Director, PNED; and Director,,
l PNSD The General Manager, PNPPD; Director, PNED; and Director, PNSD are i
responsible for identifying, cont. rolling, assisting in providing dispositions, and resolving nonconforming items at the plant in accordance with written approved procedures which conform to the 4
requirements of this section. In addition, the General Manager, PNPP, i
and Director, PNED, are responsible for analyzing and trending failures of plant equipment.
Additionally, the Director, PNED, is responsible for providing technical reviews of nonconformances, obtaining information from responsible
{
design organizations, and assisting in developing dispositions to nonconformances when requested.
17.2.15.3.2 Director, Perry Nuclear Assurance Department 4
s The Director, PNAD, is responsible for the identification, documentation, and segregation of nonconforming items at the plant.
4 This director is responsible for reviewing nonconformance dispositions for adequacy, providing approval, performing inspection of replacement, reworked or repaired items, and closeout of nonconformances generated at the plant. -furth:r, threush tuview ano approval of plaui oda.ir.is t ra t ive C'
6 4
Revision 6 17.2-56 March, 1994
PY-CEI/NRR-2079L Page 24 of 30 4
J' control procedures and vendor / contractor A rogram audits, and inspections, the Director, P D, shall verify the adequate implementation o conformance control both at the plant and in the Revision 3 17,2-56a March, 1991
1 PY-CEI/NRR-2079L I
Page 25 of 30 W cilitie: ef vand^
and centroeterex The Director, PNAD, is responsible for the performance and reporting of periodic quality trend analysis of nonconformances.
s 17.2.16 CORRECTIVE ACTION 17.2.16.1 Policy Heasures shall be established which ensure that' conditions adverse to j
quality, such as malfunctions, ceficiencies, deviations, defective material and equipment, and nonconformances be identified promptly and j
corrected. The cause of significant conditions adverse to quality shall be determined and corrective action shall be taken to preclude repetition. The identification, cause and actions taken to correct conditions adverse to quality shall be documented and reported to the appropriate levels of management.
~
Significant conditions as delineated in 10 CFR 50.72 or 10 CFR 21 shall be reported to appropriate management levels within the affected organization.
17.2.16.2 Requirements Procedures shall be established which detail and implement at least the following corrective action system measures:
a.
Conditions adverse to quality shall be corrected and shall be evaluated as to the significance of the condition.
b.
Significant conditions adverse to quality shall have action taken to prevent recurrence.
Nf 6L(/Q A (-d hC[/h I ~l. A. lb. 3, 3 M 4 V\\4 V,
hM 1
i k m anag te, gas,.s kale v evi fy St. a dqwds im ples e.11a hm t
of nam fo rma c e. wk\\ b A J k.
ant andsh,L Revision 7 Fc, c; \\itie3 o F mJo/$
17.2-57 March, 1995 w ck c m 1 n c y o r s,
__..m PY-CEI/NRR-2079L Page 26 of 30 Follow-up activitica shall be conducted to verif:r implementation of c.
corrective action and to close out corrective action documentation, d.
Corrective action doc. mentation shall include at least identification, cause and action taken to correct conditions adverse to quality and preclude the recurrence of significant conditions adverse to qualityt Significant deficiencies, nonconformances and defects, shall be e.
evaluated for possible reporting to the NRC. The PORC and the NSRC shall also assess these significant deficiencies.
i 17.2.16.3 Responsibilities and Authorities 17.2.16.3.1 Perry Nuclear Assurance Department PNAD shall verify compliance with corrective action measures through audits, and inspections of internal and external organizations, contractors and vendors, and through other QA evaluation and control techniques, such as quality trend analysis.
17.2.16.3.2 General Manager, PNPPD; Director, PNSD; and Director, PNED The General Manager, PNPPD; Dirdctor, PNSD; and Director, PNED, are responsible for assuring that identified conditions adverse to quality are promptly corrected and, when significant, measures are taken to preclude re'currence.
17.2.16.3.3 Director, Perry Nuclear Assurance Department The Director, PNAD, is responsible for ensuring the establishment of the corrective action procedure and QA corrective action measuresf ad establishing the appropriate interfaces with Perry departments for effecting Revision 7 17.2-58 March, 1995
PY-CEI/NRR-2079L Page 27 of 30 correctiveactionwithcontractors, vendors, agents,andconsultantsf.
/resolvingcorrectiveactionimpasseswithcorporatemanagementfand f
delegating stop-vork authority to appropriate PNAD personnel and agents 17.2.16.3.yI Director, Procurement Department, CSC l
The Director, Procurement Department, CSC, is responsible for ensuring the establishment of commercial,c,orrective actiop measures in procurement documents, whenever possible, and in Perry Administrative procedures and instructions.
}
17.2.17 OUALITY ASSURANCE RECORDS 17.2.17.1 Policy Quality records for items and activities covered under the scope of this document shall be identified, reviewed, retained, and retrievable.
These requirements are imposed on all organizations performing safety-related functions.
Quality record systems shall be described and controlled by approved written procedures and instructions and verified by PNAD through inspect' ion and audit.
l 17.2.17.2 Requirements The procedures established for tho generation, collection, storage, maintenance, and retrieval of the Perry quality records shall meet the following minimum requirements:
l Sufficient records and documentation shall be maintained to provide a.
evidence of the quality of items and/or activities affecting f
quality.
I]. 0. Ilo 3 4 Wun6gQ/,0V0l$Y 0S$QfQnCL C.Y~RM ik manapc, ons, h aspm.s;h \\e For Revision 3 17.2-59 March, 1991 l
}
PY-CEI/NRR-2079L Page 28 of 30 g.
Documented measures shall be established to assure retrievability of re ords and to preclude their loss by such means as duplicate files, microfilming, etc.
4 17.2.17.3 Responsibilities and Authorities a
17.2.17.3.1 Director, Perry Nuclear Assurance Department l
1 4
i j
The Director, PNAD, is responsible for approving the general j
requirements for the maintenance of quality astsurance records; reviewing
^
and approving major participating organizations' procedures for the maintenance of Quality Assurance records; establishing a program for the identification, storage, retrieval, and maintenance of Quality Assurance records including inde'xing, permanent storage, maintenance, and retrievalsf.
erforming planned and periodic audits to verify adequacy and implementation of GA record requirements by both internal organizations and external suppliers.
l19. M. 3.1 MQM R f, h06 l b[ kM4M6 SR 1ht (nang er, yes, b respm s fbl e. Fo r Revision 7 17.2-62 March,1795
PY-CEI/NRR-2079L Page 29 of 30 i
3 Audit frequencies shall be based upon the status and safety importance 1i of activities, degree of previous experience, consistency of overall i
coverage, unique testing / operating activities, and the need for follow I
up on previous audit findings. Audit frequencies, as a minimum, shall be those imposed by the commitment to Regulatory Guide 1.33 and ANSI N18.7.
l Audits shall be performed in accordance with pre-established written procedures or checklists, and shall be conducted by trained personnel having no direct responsibilities in the areas being audited.
Audit results shall be document reported to management having responsibility for the area being audited, and require correc_tive action to be initiated to correct any deficiencies.
The OA organization conducting the audit is responsible for conducting follow-up actions including reaudit of deficient areas, as required, to assure correction of the deficiencies.
1 Audits shall verify compliance with applicable criteria of 10 CFR 50, Appendix B and 'shall include verification, as applicable, of i
indoctrination and training programs; interface control among internal l
organizations and major contractors; corrective action; calibration; nonconformance control systems; and, the implementation of USAR commitments; and, activities associated with computer codes.
.17.2.18.3 Responsibilities and Authorities M4hage6 00G. \\ gYl kSk/LO n C L b O M.
L 17.2.18.3.1 Oirecter, P:rry Mac1com Assa ance Ocys t ca:
C t% ctg er, Q %
, The Circc:ct, PN!.0, is responsible for providing for a system of planned andci;:.2i.auditsoforganizationsperformingsafety-related f
activities + c;iding for a sy;;ca of plaar.cd ur.d pcricdic endit uI-T VIUdl vendorsh ' eth:: crganizatica ; rM - Mg q" lity related contractors f oc ivitics; and periodically evaluating and reporting on the status l
Revision 3 17.2-64 March, 1991 1
. _.. ~..
-.. = _ _ _.
PY-CEI/NRR-2079L Page 30 of 30 l
VICE PRESIDENT f_
NUCEAR PERRY l
1 l
l l
PERRY NUCLEAR I
ASSURANCE DEPARTMENT l
1 l
I I
I i
I
~
o:lAUTY CONTROL QUAUTY ASSURANCE INDEPENDENT SAFETY OUAUTY SERVICES SECTION SECTION ENGINEERING SECTION l
MANAGER MANAGER GROUP MANAGER MANAGER l'
l SWF STAFF
{ SWF STAFF l
l PERRY T P. A t & \\ M (r l
S ECTJo d (D A(V A 6-G(L STSFF (Rev. 7 3/95) i O
PERRY MUCLEAR POWER PLANT THE CLEVELAND ELECTRIC ILLUMINATING COMPANY l
Perry Nuclear Assurance Department Organization 4
Figure 17.2-2 l
IIOV-12-90 TJE 15:06 PERRY LICENSING FAX NO. 2162808001 P 02 RGY
_~
~
F EFIRY NUCLEArt POWER PLANT Man Morase-C CE NTert Foto PO BOX 97 PERR(, OHIO 44081 M NTH, OH10 443e1 i'/16) PW4F37 November 12, 1996 VY-CEI/URR 115L United States Nuclear Regulatory Conmission Documnnt Control Desk Washington, D.C.
20555 1%rry Nuclear Power Plant i
2 Docket No. 50-440 10CFRS O,54 (a) (3) Organization Change for the Perry Nuclear Assurance Department and the Perry Training Section - Supplemental Information Lsdies and Gentlemen On July 23, 1996, Perry submitted letter PY-CEI/NRR-2079L, pursuant to the provin t ons of 10CFR50.54 (a) (3), to request rwview of proposed changes to the Ferry N.1 clear Assurance Department (PNAD).
tbsder the proposed change, the Perry Training Section will be transferred from Lie Perry Nuclear Services Department (PNSD) to PNAD.
Several Nuclear Quality Assurance Program responsibilities will be reassigned from the Direct.or, PNAD to the Rnager, Quality Assurance Section as a result of PNAD accepting training trogram responsibilities.
.i tulephone conference was held on October 11, 1996 between NRC and CEI staff to c.ineusn 7.testions regarding the submittal. Attachment 1 to this letter provides the additional information and modifications to the submittal as a result of the CetnMr 11 conversation. Attachment 2 provides the marked up USAR pages for the Chapter 17,2 changea provided in the original submittal. These pages supersede la3e.n 1 '., 12, 13, 14, 16, 21, and 25 of the July 23 submittal.
If you have questions or require additional information, please contact Mr. James D. Kloosterman, Manager - Regulatory Affairs at (216) 200-5833.
Vary ttuly youra, Pemm%
Lew W. Myers Vice P;:0aident - Nuclear WOce:
( Mvr; Compo+ts GM 0 C OfCific tilumf0fTg IC 43 ' F 117
flTh12"6 TUE 15:06 PERRY LICENSING FAX N0. 2162808001 P.03 i
PY-CEI/NRR-2115L Page 2 of 2 l
Attachaents cc: FEC Region III hTC Pesident Inspector PR$ Project Manager i
i l
i i
r 1
I
%V-12-33TJE15:07 PERRY 1.10ENSlHG FAX N0. 2162808001 P.04 i
PY-CBI/NRR-2115L Page 1 of 1 Insar: the following changen where indicated in Attachment 2 of letter F7-c81/fiRR-2079L:
Pages 17.2-11 Part 1/.2.1.3.2.2 T&asn t<ri responsibility for qualit.y assurance training from the Director, PNAD to the Kulager, QAS. Delete Director, FNAD responsibility requirement g and add it to.he list of Manager, CAS responaibilities given in INSERT A to page 27.2-12.
I'3 3 t 17.2-12 P.a rt 17.2.1.3.2.2 i
celet.a t he word " experience" appended to the end of Manager, CAS qualification rg:f r.1%r.t b.
1 Page 17.2-13
! art 17.2.1.3.2.2 The prograph following item d will be mcved to start at the left margin.
)
I' age 17. 2 -21 Part 17.2.2.3.2 Inner: ';he following paragraph after the responsibility heading:
"The Mr.ager, QA8 maintains overall responsibility for the content and quality
)
of the Operational QA Program as dascribed in this chapter and shall exercise 1
Iinal approval authority for any changes to the QA program description prior to i np1 m ier.tation. "
)
tage 1*1.2-5.,
1% rt 1.7. 2.13. 3. 3 i
1 Add t.ht phrase "thttugh conduct of audits" to new paragraph 17.2.13.3.3 J ndicating that verification of handling, storage, and shipping requirement.s is i
done through audits, Page 17.2-57 Part
)'.2 15.3.3 Add t ha phrase "through conduct of audits" to new paragraph 17.2.15.3.3 indicar:Inq that verification of nonconformance controle is done through audits.
r l
i
- jf/.1'N3 ',)': 15:07 PERRY 1.lCENSlHG MN 2
} PY-CH1/NRR-2115L An.A= -a* 2 Page1 cf 3 PY~CEI/NRR-2079L
- Indicates area ofchange Page 1I of 30 t.
Provide for the review and approval of the QA p rogram of contractors providing services, and of vendors supplying materi l j
parts or components covered by the scope of this document a s, Provide for review and approval of procedures prepared b c.
organizations when these procedures control or exercise an eff' y other upon an activity that falls within the scope of this docusedt ect d.
Provide direction and supervision of the PHAD organiz ti a on.
Haintain a vorking interface and communication with the NRC c.
organizations, consultants, ' contractors, vendors, and others as
, other i
required to effectively execute the policies presested in this description 'of the QA Program.
Provide for a system of planne'd and pe'riodic audit and inspection of organisations, contractors and vendors performing actW that fall within the scope of this document.
e8
(
hlfv'idefo g
systes lanned periodi
- }c
/assur ternal audit to.
pf tation
"*f
- **j*OA polle b
, proced s and I
i f
2;^
/
.w f.
Estab5sh x
T
~.
sure, thi:.
uous'ialhlesenta' ti$' n
~
indo ran nation and t sig ppogram for PN
/QC personnel an y vsure that a ity asirurance indoc nation is provid
- 2.. A-s.. appropr e personnel outside t A organization.
o i.
Je2ularly r ort to t ce Presi t, Nuc1
- Perry, stat i
of qua y acti
, and b g to his tion i iate si iificant q 11ty-rela problea eficien
/,
, any i
17.2-11 Revision 3 March, 1991 i
i
l
'm;p ; v 3 R !L:08 PERRY 1.ICENSlNG FAX NO. 2162808001 P. 06 t
PY-CEf/ RR.2tl5L
~~
~~
>~m 2
{
Page 2 of 8 PY-CET/NRR-2079L j
- Indicates area of change Aecachiment 3 h
4f,( bd(/thp (jge10 dd Cil ifm g Page 12 of 30 L
Cm f. I~l. 'A ' \\\\
f j.
Provide for QA reviev and concurrence of safety-related pl' nt a
modification and maintenance work authorizations. This includes
{
the review of associated design documents to ensure proper review and approval, and inclusion of necessary quality assurance requirements.
i j.
Provide for QA review and apptwal of procurement documents genacated for the acquisition of materials and services that fall within the scope of this document.
~
j.
Provide for and maintain Quality Assurance rQcords generated by PNAD until such time as they are turned over for permanent storage.
7-
[ r/, Pejitidical _ evalua e.1[hd te on th atus a ad cy of
(._/Quali Assur Progr o appr ate es
[J j
k p' l
J).
Perform receiving inspection activities at the plant site.
J.
Provide for adeggate levels of inspection and surveillance of plant activities.
g
^
j.
Provide',the.resourEes necessary to. ensure that the' Independent 4
I SafetyhBdg ;.;..
., - u ; g3roup can.pe;rform theVactivitiinat'dgeribed fin
.c ineerin n
Appendix 1A,. Item 1.B.1.2:and.Section 13.'4.3.
l j/.
Provide general and procedural adelaistrative services, document control and DeVelo,[n. rhcords management. [td74M b4.S(d CA 16 PNMC M'
em Tr aNih G or h[P.<uq d admenfs.
awed
'(
lification requirements for the AEm, M, arth; d are:
/
3F,gT /; p manag er, QAS, Management experience through progressive assignment of increasing a.
responsibility.
- DELETE b.
i'ernal degree in a science or engineering discipline or.
prof.essional registration or equivalent Ohj '. m C.i_.
{
17.2-12 Revision 7 March, 1995
X 1 M 6 1 R 15:12 PERRY LICENSING.
FAX N0, 2162808001 P.01 i
PY-CF.1/NRR-2115L PY -CEI/NRR-2079L And et2 Pagc3 0f 8 Page 13 of 30
- Indicates area ofcimge I!1 SEPT A The cvs:ific ' responsibilities of the Manager, QAS, include the following:
Imide for a system of planned and periodic internal audito to assure the sap e;entation of QA policies, procedures and instructions by organization eidre.r.ced in the Operational QA Program.
b.
Legaltsrly report to the Vice President, Nuclear - Perry, the status of Quality-related probica or deficiency. quality activitiles, and bring to Atturance Program to appropriate management.Periolically evaluate e.
d.
Init.iating stop work, or control further proce' sing, deliveIy, or instdlation of nonconforming material or activity as described in the s
app 1kable quality Assurance procedures and instructions and in the appiicable plant procedures and instructions.
, - ~,,. ~ -
1
(
U-16 Q Md Q,%W6 1h &. C onh'n U 00 5 M PfMfHYaflok t
3 pn indochincdde bd trai6ihg proyam kr PNAD elst evsonnd and assure shar a gua\\ity ouuranca in doctdadion is (>rovid u0 to o.ppropriaie H.y..P'annel ouhide +ke Q A eqaniptfo A.
l
- MD 9
e
Vfh1246 'lUE 15'12 PERRY 1.10ENSlHG M H0. 2182808001 M
PY.CF.VNRR 2115L
- py'_CM/NRR-2079L
+
Page 4 of A Attachsent 3
- Indicates area ofdiange Page 14 of 30 plant experience in the overall, implementation of the Quality tesurance Program.
A minimum of 1 year of this 6 years experience thall be related technical or academic training A maximum of 4 years experience may be fulfilled by related tecimical or
.acadenic training.
4 d.
Training in 04 policies, standards, regulations, and practices
.a The !)irector, PNAD, is assisted in carryl,ng'out his * *
- tnrponsibilities by a staff orgeaised into sections to provide 1.
g.
t-adequate co'verage of procurement, saanufacturing, inservice (U
' inspection, refueling, antat'enance, repair, modification M
, and
@Db operation of Perry (Figure 17.2-2). The staff' includes required lexportise to perform addit, quality engineering, surveillance, and inspection functions.
[eN; aged to augment the PNAD staff.In addition, qdality assurane'se PtIDshallmaintaindirect 4
! control over any quality assurance agent.
{
17.2.1.3.2.2.1 Hanager, Quality Assurance Section The F.a.itger, Quality Assubce Section esystemofplannedpehiodicinternal is responsible for' implementing ts and surveillances. Sec' tion activitics include inpu't to.and review o1 procedures and' corrective ~
act!on pograast revieving changes to Operations CA Plant curveillance of plant operation 4:1[dI oviding administrative ' support for PNAD.
17.2.b3 2.2 2 M=%ur, Quality control Section..
/
R e M w tsr, Quality' Control Section, is responsible for review and appromi of procurement documents; maintains a program for approval
, audit nmt curveillance of suppliers; and
- b45 C')t/d.l Af.Jpte sib l}iff for Veri /p dnphe.m&duk ef k Qu&ts ssub,s do e.ffdik a
cs %ya H e.
17.2-13 Revision 3 Harch, 1991
"0V M El 15:13 PERRY LICENSING FAX N0. 2162808001 P,03 PY-CE1/NRR-2115L
.PY-CEI/NRR 207'L 9
i Patc 5 of 8 Page 16 of 30
- Indicates area of change
/. 7 corrective action which may be deemed necessary, as a result of
.bese yearly assessments, shall be formally identified and tracked te resolution.
g MqnQ K Q40dihj d55tV4M4 NC NA4 M6) g'
- u. u.3.2 e =.1 renecae -As-m=nm.= = c
^ ? x,anager,QAs,
'Che N reeter, P"J.D, as th~e official given direct responsibility for incif ying the effoetive implementation of the Perry Operational QA Progrri, shall establish and impicment a formally documented and l
prm+irally controlled program to evaluate and report to the vice Presiicat, Nuclear - Perry on,the. adequacy and continued effectiveness of ik overall Perry.00A Program. Reports of audits performed by PNAD or teir agents, and quality trend analysis vill provide the basis for l
th b <saluation. Corrective action shall be implemented by responsible
.ians rwent, as deemed appropriate, when analysis reveals adverso quality trmh. 1hese actions may involve specific actions t'o provide j
con;11ance with the QA Program, and may include follow-up audits or revD.fon to the OQA Program. Inc'41entation and close-out of corrective oetin: shall be monitored by the Dieest::, "?Br to assure timely corretionandcompliang.
M4H4f f/j OMj i
17 L 2.3.3 '
Dire'ctoE/CdhEral}Handgerf of Edch Orgeitizat$6,n;
'fh i irector/ General lianager.of'ieakorganization is.rEponsible for in:Ga renting training and indoc'trination programs for their respective mic-teations which moet the requirements in Section 17.2.2.2., Item g.
- 17. L 2.4 Delegated Authorities QWiiy assurance programs and implementing procedures for suppliers or cent: meters providing materials and services for Perry which are covered I
und:: the scope of this OA Program shall be subject to reviev and c.cca; tance by PNAD prior to the commencement of any activity covered Wcr the scope of' this OA Program. Procurement documents shall.
Revision 7 17.2-21 March, 1995 1
0 0
!DV-12-93 TUE 15:13 PERRY LICENSlHG FAX N0. 2162808001 P.04 l
FY-CEI/NRR-31iSL Anschment 2 Page6cf 8
- bdestes area ofchange IN!;ERT AT THE DEGINNING OF 8HCU ON 17.2.2.3.2 The M enger, QAS maintains overall responsibility for the content and quality of the Operational QA Program as described in this chapter and shall exercise final l
approval authority for any changes prior to implementation.
1 1
i
l@]246 Ti'E 15:14 PERRY 1lCENSlHG FAX N0. 2162808001 P.05 PY-CEl/NRR 2115L PT-CEI/NRR-2079L A"*hra*"e 2 page 7 of 8 Page 2I of 30
- huticates area ofchange 17.2.13.3.2 Director, Perry Nuclear Assurance Department l
The Director, PNAD, is responsible for receipt inspection verification l
of specia'l handling and packaging maintenance during sh' ipment, and conducting inspections and -addo verify the implementation of handling, storage and shipping requirements.
~,..
t
/
17.2.14 INSPECTION, TEST AND OPERATING STATUS l
[
1742.14.1 Policy l
i A program chall be established to indicate the inspection, test and operating status of structures, systems and components covered ttnder the scope of this document.
The status of safety-related structures, systems and components shall be controlled in accordance vith approved procedures.
These procedures shall include the use of appropriate tags, markinga, lists, logs, diagrams, or other suitable means, to assure that required inspections and tests are satisfactb,rily comple$ted to prevent inadvertent bypassing of required in'spectionIInd, tests,andito' prevent Isabvertent-operatiori.1 l
y...
- 4 17.2.14.2 Requirciuents
'T Ou do i\\ d d d o f g d ' s d
An acceptable inspection, test alnd operatlng status program shall l
includes 5
The identification of inspection, test and operating status of a.
structures, systems and components.
b.
Procedures which include controls for the application and removal of inspection and velding stamps, and other status indicators such -
as tags, markings, labels, and stamps.
M. A.13, 3. 3
[d
) tk mana 4 &14fF h NY j
A r., Q U, d a d w iT M M b "
R f
koraln3, cays a s q q a g u rr w e s w. 1991 17.2-52 sion 3 March
J K
'fN-12-M Tile 15:14 PERRY 1.lCENSING FAX N0. 2162808001 P. 08 i
i PY CFWNRR-2 t l5L PY-CEI/NRR-2079L l
Page 8 of 8 At.tachment 3
- Indicates arca of change Page 25 of 30 i } inc411+1es a f = h : er.d-contraceeeer The Director, PNAD, is responsible for the performance and reporting of periodic quality trend analysis of nonconformances.
- - >,17216 CORRECTIVE ACTION 17.2.16.1 Policy i
Heasures shall be established which enstre that' conditions adverse to quality, such as malfunctions, ' deficiencies, deviations, defective material and equipment, and nonconformances be identified promptly and corrected. The cause of significant conditions adverse'to quality shall l
be determined and corrective action shall be taken to preclude repetition. The identification, cause and actions taken to correct conditions adverse to quality shall be documented and reported to the appropriate levels of' management.
Significant conditions as delineated in 10 CPR 50.72 or 10 CPR 21 shall j
be reported to appropriate'eanagement levels vithin the affected organization.
Y 1
17.2.16.2 Requirementu.v
.2'
.i c
Procedures _ shall.be established which detail'and-implement at:least.the i
following corrective action systdm measures:
Conditions adverse to quailty shall be corrected and shall be a.
evaluated as to the significance of the condition.
b.
Significant conditions adverse to quality shall have action taken to' prevent recurrence.
- 3. 2. s. 3. 3 rnanag v,.o udty asswas f4 '
As-manag v, QAs,.s koll veM & 4ek uxds dnp[es uta hk 1
n af neum racmance ce%\\ 6A cd h pant a;,fg), A-
%; \\itAs o F vwJoi n
i.2-57 Harch, 1995
- cf cm PNttfor Through conduct of audit 3.
- AD l