ML20195B259
ML20195B259 | |
Person / Time | |
---|---|
Site: | Dresden, Byron, Braidwood, Quad Cities, Zion, LaSalle |
Issue date: | 05/19/1999 |
From: | COMMONWEALTH EDISON CO. |
To: | |
Shared Package | |
ML20195B233 | List: |
References | |
CE-1-A, CE-1-A-R66A, NUDOCS 9905280201 | |
Download: ML20195B259 (30) | |
Text
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ATTACHMENT B Revised Pages of the Comed Quality Assurance Topical Report Note 1
The affected pages of the QATR Revision 66a have been revised to show the proposed changes. Deleted text is shown as strikethrough and new text is shown as underlined. All changes are also annotated with a vertical bar in the margin as shown with this note.
9905280201 990519 DR ADOCK 0500 0 I
m ORGANIZATION SECTION 1 They fulfill t,hese responsibilities through a staff that includes:
. Materials Management Supervisor (Braidwood, Byron, Dresden, LaSalle & Zion)
Site Materials Manager (Quad Cities)
Office Supervisor (Braidwood, Byron, Dresden, LaSalle & Zion)
- Office Support Supervisor (Zion).-
.. 3.4.1.3.3.1.5.1 ' Materials Management Supervisor Site Materials Manager
' These positions coordinate parts requirements, specify'and evaluate parts, procure all materials for the site, ship and receive material, and control the onsite inventory.-
3.4.1.3.3.1.5.2 - Office Supervisor
' Office Support Supervisor
' These positions are' responsible for maintaining quality assurance records and providing clerical support to the station.
3.4.1.3.4 NSRB Chairperson The NSRB Chairperson reports directly to the President and Chief Nuclear Officer. The Chairperson is independent of operations. He is responsible for reviewing and approving the findings and recommendations of the NSRB and advising the President, NGG and Chief Nuclear Officer on the adequacy and implementation of Comed nuclear safety policies and programs. The chairperson fulfills these responsibilities through the activities of the Nuclear Safety. Review Boards.
- 4. REFERENCES The following references were used in the generation of this Section. The Company's !
- commitment to particular revisions of these standards is contained in Section 2. Specfic r6rra fo" the r q"!rement: cre cont:in^d in the O.A Progr:m Ort b ::.
' ANSI /ASME NQA-1 -
- ASME Code Section lil, NCA-4000 -
ANSI N45.2.8 ANSI N45.2.1 -
ANSI N45.2.9 ANSI N45.2.2- -
ANSI N45.2.15 ANSI N45.2.3 -
ANSI N45.2.20 ANSI 18.7 ' -
ANS 3.1 l I
SNT-TC-1A
- Page 1-24 REVISION 66a 1/29/99 t
l
QUALITY ASSURANCE PROGRAM SECTION 2
. l
- 1. POLICY It is the policy of Commonwealth Edison Company to have a Quality Assurance Program that:
- a. Complies with the ASME Code, Federal Regulations, and other requirements.
- b. Defines and documents the requirements and commitments that, when implemented, protect the health and safety of the public and our workers.
- c. Serves to protect the interests of Comed.
- 2. RESPONSIBILITIES All organizations involved in the production of nuclear power are governed by this Program and are responsible for carrying out the requirements of this Section. These organizations include:
Nuclear Generation Nuclear Stations Site Regulatory Assurance Site Material Management Site Engineering Nuclear Engineering Services j Nuclear Support Organizations
. Nuclear Regulatory Services Nuclear Oversight' i
Procurement :
Corporate Security System Materials Analysis Techlabs
- 3. REQUIREMENTS l 3.1 General Either regulation or Comed, independent of the regulations, requires the activities of the Quality Assurance Program to be performed. As such, this Program meets the interd of the word "shall" as used in the regulations and ANSI and ASME documents.
This Program applies without limitation to safety related or ASME Code structures, systems, components, and activities. It also applies, as described in Section 19, to l Page 2-1 REVISION XX X/XX/99
QUALITY ASSURANCE PROGRAM SECTION 2 1
reg &to'y re!:ted other structures, systems, components and activities to a degree consistent with their importance to safety. Section 19 also references the cuality rea'uirements that are to be applied to Zion Nuclear Power Station (ZNPS) in its permanently defueled condition. The reauirements in Sections 3 throuah 18 no lonaer acolv to ZNPS.
This Quality Assurance Program is in effect during all phases of the design, fabrication, erection, testing, operation and decommissioning of Comed's nuclear power plants.
" Operation" includes operation, maintenance, repair, modification, refueling, and in-service inspection.
The Quality Assurance Program takes into account the need for special controls, l processes, test equipment, tools, and skills necessary to attain the required quality and the need for the verification of quality by inspection and test.
This Quality Assurance Program complies with the quality requirements of:
- a. 10CFR50
- 1. Paragraph 55a 4. Appendix A
- 2. Paragraph 55(e) 5. Appendix B
- 3. Paragraph 59 6. Appendix R
- b. 10CFR21
- c. 10CFR71 Subpart H
- d. 10CFR72 l e. ASME Boiler and Pressure Vessel Code Section lll l (NCA 4000), Division 1 and Division 2,1992
- f. ASME Boiler and Pressure Vessel Code Section XI,1992
- g. ANSI /ANS 3.2,1988
- h. ANSl/ASME NOA-1,1989 (1a,1b)
I i. ANSI /ASME NQA-2,1989
- j. ANSI /ANS 3.1,1981 This Quality Assurance Program complies with the programmatic quality requirements of the following standards. Specific work practices and acceptance criteria are reflected in implementing procedures.
- a. ANSI N101.4,1972
- b. AWS D1.1-80 l c. IEEE Standard 323,1974 1
Because of compliance with the above list of standards, this Quality Assurance Program also complies with the regulatory positions of the following Regulatory Guides:
- a. 1.26 Rev 3 e. 1.54 (6/73)
I b. 1.28 Rev 3 f. 1.68 Rev 2 l c. 1.29 Rev 3 g. 1.143 Rev 1 Page 2-2 REVISION XX X/XX/99 l
QUAUTY ASSURANCE PROGRAM SECTION 2 )
Comed documents these plans in appropriate communications, approvals, instructions, and procedures.
3.2.2 Controlled Conditions Activities described in this Program are accomplished under controlled conditions.
Controlled conditions include appropriate equipment, qualified personnel, suitable environment, and use of appropriate procedures. Other sections of this Program describe these controlled conditions.
3.2.3 Program Planning An Audit Program is planned and conducted in accordance with Section 18 of this Program.
A Design Program is planned and conducted in accordance with Section 3 of this Program.
A Procurement Program is planned and conducted in accordance with Sections 4, 7, 8, and 13 of this Program.
3.3 Program Description Comed's total program for providing administrative controls and quality assurance is !
incorporated in many diverse documents. This document is the QA Program and is the i policy directive for Nuclear Quality Assurance. At the interdepartmental level, Nuclear Operating Directives, Nuclear Station Procedures, the Special Process Procedure Manual, and the Nuclear Oversight Procedures describe the implementation of the QA Program. At the departmental level, approved implementing procedures and i instructions are written to the extent necessary to implement the quality requirements.
Line, staff, administrative, and quality oversight organizations issue these implementing i procedures. All activities affecting quality are described in sufficient detail to assure quality.
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3.4 indoctrination & Training Personnel performing activities affecting quality are oriented, indoctrinated, and trained as necessary to assure achievement and maintenance of suitable proficiency. Training e
' Page 2 4 REVISION XX X/XX/99
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QUALITY ASSURANCE PROGRAM SECTION 2 s.
l 3.8 Quality Assurance Manual The Company Quality Assurance Proaram is described in the Comed Quality Assurance Manual contained herein.--conciet: Of this Oustity A::urance Program {
document, and the Que!!!y A::urance Program Databacc. The Ou:!!!y Accurance j Program Datab 00 contains; ?
l . The Ou:!!!y A::urance Program, l l b. The pertinent part: Of :Ource d^Ns-l c. Cr00: references among the:0 0'0mente. ;
- d. Cross-references to the responsible depadment: and implementing procedures.
The QA Manual is made available to Company personnel, NRC personnel, the Authorized Nuclear Inspector, and other regulatory authorities. Comed submits ]
revisions to the Quality Assurance Program document (as the Topical Report) to the i NRC for acceptance as follows:
I a. Programmatic changes which reduce commitments must be accepted prior to implementation.
- b. Substantive changes (organizational, operational, etc.) will be submitted within 30 days of effective date. I
- c. Changes, editorial changes, reassignments which do not reduce commitments may not be submitted at the time of the change, but are submitted at least once every two years. I l
The Authorized Nuclear inspector Supervisor accepts proposed changes before they are put into effect. Changes are distributed.
- 4. REFERENCES The following references were used in the generation of this Section. The Company's !
commitment to particular revisions of these standards is contained in this Section. l Specific reference: for the requirement: !!:ted in Article 3 of trus-Section are contained h 5 0 C.A R O^ge'", 0
- 2 000.
10CFR50 APPENDIX B I 10CFR72 ANS!!!<SME NOA-1 ANSI N18.7 ANS 3.2 ANSI N45.2 ANSI N45.2.11 Page 2-6 REVISION XX X/XX/99
I DESIGN CONTROL SECTION 3 l a
- 4. REFERENCES J The following references were used in the generation of this Section. The Company's l commitment to particular revisions of these standards is contained in Section 2. -
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I 10CFR50 Appendix B l ANSI N18.7
- ANSI /ASME NQA-1 ASME Code Section lil, NCA-4000 1
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9 I
l 1
1 l
l Page 34 REVISION XX XIXX/99 l
, PROCUREMENT DOCUMENT CONTROL SECTION 4
- 4. REFERENCES ;
The folloiuing references were used in the generation of this Section. The Company's commitment to particular revisions of these standards is contained in Section 2.
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in tM O.A Pre;p= Database-10CFR50 Appendix B ANSI /ASME NQA-1
- ANSI N18.7 ASME Code Section 111, NCA-4000 ANSI N45.2 .
l l
Ii 1
Page 4 4 REVISION XX XIXXI99
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INSTRUCTIONS, PROCEDURES AND DRAWINGS SECTION 5 h C:z;r.y rrr';;.; ::;:.-:!M9ty fr :;::5: rd;- .de er-:@ 5 0"Mty
- 3. REQUIREMENTS 3.1 Preparation and Review -
j Procedures shall be prepared, reviewed, approved, and used as prescribed, in writing, and shall contain sufficient detail to perform the required actions. Where appropriate, .
these procedures will include checklists containing the necessary attributes to be 1 observed or measured.
The procedures will be independently reviewed and evaluated by other involved departments with interface responsibilities and the comments forwarded to the issuing department.
l 3.2 General. l Operation, maintenance, or modification of equipment shall be proplanned and ,
performed in accordance with written procedures that are appropriate to the j circumstances and that conform to appiicable codes, standards, specifications and criteria. When ASME Code work is involved, these documents shall include applicable code requirements and shall be made available to the Authorized inspector for review <
and insertion of hold points, as applicable.
Temporary procedures may be issued to provide guidance in unusual situations that are not within the scope of the normal procedures. - Temporary procedures shall be subject to review and approval, and shall include designation of the time period during which they may be used. In the event of an emergency not covered by an approved procedure, authorized personnel shall provide appropriate direction to minimize personnel injury and damage to the facility and to protect the health and safety of plant personnel and the general public.
3.3 Procedures and Progr6ms !
NOTE: The requirements contained in all articles and sub-articles of 3.3.1 and 3.3.2 1 apply to Braidwood, Byron, Dresden, ansLQuad Cities ahstations. These I requirements were transferred here from the Braidwood, Byron, Dresden, ADsLQuad Cities and4en-Technical Specifications to meet administrative commitments resulting from the Technical Specification Upgrade and improvement Programs. Similar requrements exist for LaSalle. Refer to the most recently approved amendment of i LaSalle 's Technical Specifications for applicable requirements. ;
Page 6-2 REVISION XX XD0099 !
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INSTRUCTIONS, PROCEDURES AND DRAWIN28 SECTION 5 i 3.3.2 Temporary Changes 4
. Temporary changes to procedures required by 3.3.1 may be made provided:
- a. The intent of the original procedure is not altered.
- b. . The change is approved by two members of the plant management staff, at least one of whom holds a Senior Reactor Operator's License on the unit affected. -
- c. The change is documented, reviewed, and approved in accordance with 3.3.1 within 14 days of implementation.
- 4. REFERENCES The following references were used in the generation of this Section. The Company's commitment to particular revisions cf these standards is contained in Section 2. 4 S;::".:::' :r::: fr 5 rgf =:r. : !!:'ed ^ tic!c 3 c' $!: Srd!= == =te!M in l 5 O.A Prv= D-'9 re.
10CFR50 Appendix B 10CFR50.55 ASME Code Section Ill, NCA-4000 -
ANSI /ASME NQA-1 ANSI N18.7 ANS-3.21988 ANSI N45.2 ANSI /ANS 3.2 .
ANSI N45.2.11 ANSI N45.2.13 Facility Operating Licenses (Technical Specifications)
Page64 REVISION XX X/XX/99 1
)
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DOCUMENT CONTROL SECTION 6 The programs in place to sci.si.piish the procedure reviews include: the plant modification program, the operational experience feedback program, the procedure foodback process, the integrated reporting / corrective action program, the technical specification and updated final safety analysis report revision programs, the vendor information program, and the commitment management and tracking process.
Provisions shall be established to ensure that infrequently used procedures are reviewed prior to use, unless they have been reviewed within the previous two years.
The reviews are accomplished by individuals other than the originator, knowledgeable in the area affected by the procedure.
Document controls required by ASME Section lit, Division 1 and Division 2 are as stated in the ASME Code Interface.
ASME Code documents are made available to the Authorized Nuclear inspector.
Document control' procedures shall assure that proper documents are accessible and i are being used. Obsolete documents are recalled or identified.
The scope of the document control program is defined. Examples of documents that are controlled include, but are not limited to: as-built drawings, engineering calculations, design specifications, computer codes, purchase orders and related documents, audit and surveillance procedures, operating procedures, emergency operating procedures, technical specifications, nonconformance reports, corrective j action reports, work instructions and procedures, calibration procedures, quality j verification procedures, inspection and test reports, Safety Analysis Reports, and !
Topical Reports. ,
i
- 4. REFERENCES The following references were used in the generation of this Section. The Company's 1 commitment to particular revisions of these standards is contained in Section 2. -
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5 :i -'h 5 0..^.Pr"~ = D '92:0. -
10CFR50 Appendix B ANSI N45.2 ANSI /ASME NQA-1 ANSI N45.2.11
' ANSI N18.7 ANSI /ANS-3.2 ASME Code Section Ill, NCA-4000 Letter dated December 20,1994 from M. Ring (NRC) to Site Vice Presidents (Comed)
Page 6-3 REVISION XX X/XX199
- o .
CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND SERVICES SECTION 7
- 1. POLICY This Section establishes the quality system elements and related policies that assure the quality of purchased material, equipment and services.
- 2. RESPONSIBILITIES The following organizations are responsible for carrying out the' requirements of this Section:
Nuclear Generation Nuclear Stations i Site Material Management I Site Engineering Nuclear Engineering Services Nuclear Oversight Procurement Corporate Security System Materials Analysis Techlabs i
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- 3. REQUIREMENTS 3.1 Supplier Selection 3.1.1 General Comed establishes measures to assure that purchased material, equipment and services conform to the procurement documents.
3.1.2 Comed Responsibilities The Company assigns responsibilities in the supplier selection process as listed below;
- a. The Nuclear Oversight Department evaluates the vendor's quality program.
Page 7-1 REVISION XX XIXX/99 ;
1 i
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7, CONTROL GF PURCHASED MATERIAL, EQUIPMENT, AND SERVICES SECTION 7 3.6.4 Equivalent Production / Fabrication Requirements .
Items associated with safety-related structures or systems are produced or fabricated under requirements at least equivalent to that of the original equipment, or those specified by a properly reviewed and approved revision. ,
, 3.8.5. Maintenance or Modification The Company performs maintenance or modifications.that may affect the function of safety-related structures, systems, or components in a manner to assure quality at least equivalent to that specified in original design bases and requirements, materials specifications and inspection requirements.
3.8.6 Testing or Design for Equivalence Replacement items receive adequate testing or are of a design for which experience shows a high probability of satisfactory performance. The Company considers phased replacement to permit in-service performance of a new component to be evaluated.
When used, this minimizes the possibility of a hidden deficiency producing a systematic failure.
- 4. . REFERENCES The following references were used in the generation of this Section. The Company's commitment to particular revisions of these-standards is contained in Section 2.
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10CFR50 Appendix B ANSI N18.7.
-* ANSI N45.2 ANSI /ASME NOA-1 ASME Code Section ill, NCA-4000 ANSI N45.2.13 Page 7-11 REVISION XX XIXX/99 l
l
i IDENTIFICATION AND CONTROL OF l MATERIALS, PARTS AND COMPONENTS -
SECTION 8 i
- 4. REFERENCES ]
The following references were used in the generation of this Section. The Company's !
commitment to particular revisions of these standards is contained in Section 2.
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l 10CFR50 Appendix B I ANSI 18.7 ANSI N45.2 ASME' Code Section Ill, NCA-4000 l ANSI /ASME NQA-1 ANSI N45.2.4 ANSI N45.2.8 ANSI N45.2.13 1 l
l Page 8-3 REVISION XX XIXX/99
.- 1
' CONTROL OF SPECIAL PROCESSES SECTION 9 l
. I Comed assures that qualification of Company, contractor and subcontractor ASME Code NDE personnel is verified by the ANI or ANil.
When there is a specific reason to question the ability of an individual performing special processes, the Company, the ANI, or the ANil may require re-evaluation before that individual will be permitted to resume work. ,
Individuals failing any retest will be removed from applicable operations pending requalification. !
3.4 Special Process Recorde Special process records provide evidence that special processes were performed in l accordance with approved procedures by qualified personnel. These records are l retained by the Company, or by the contractor or subcontractor as required by !
procurement documents.
Records are maintained for currently qualified personnel, processes, and equipment for l each special process.
Completion of special process records is verified by station System Engineering,.
Station Quality Control, or by the responsible Comed engineering organization.
i
- 4. REFERENCES The following references were used in the generation of this Section, The Company's commitment to particular revisions of these standards is contained in Section 2. '
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10CFR50 Appendix B ANSI /ASME NQA-1 ASME Code Section, NCA-4000 -
ASME Sec. XI l Page 9-3 REVISION XX XIXX/99
.9 INSPECTION SECTION 10
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10CFR50 Appendix B ANSI /ASME NOA-1 ANSI /ANS 3.2
- ASME Section ill, NCA-4000 Page 10-4 REVISION XX X/XX/99
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.- . l TEST CONTROL SECTION 11
~
l required accuracy, and to confirm that plant behavior conforms to design criteria. The l Company plans the start-up test program to permit safe fuel loading and start-up; to '
increase power in safe increments; and_to perform major testing at specified power . i plateaus. If tests require the variation of operating parameters outside of their normal )
range, the Company prescribes the limits within which such variation is permitted. The scope of the testing demonstrates, insofar as practicable, that the plant is capable of withstanding design transients and accidents.
The Company checks the suitability of plant operating procedures to the maximum extent possible during the performance of preoperational and start-up tests and where permitted at other times prior to fuel load. i 3.3.2 Surveillance Tests The Company's test program covers surveillance testing during the operational phase l to provide assurances that failures or substandard performance do not remain undetected and that the required reliability of safety related systems is maintained. !
3.3.3 Maintenance or Major Procedure Change ;
The Comparty performs tests following plant modification or significant changes in ;
operating procedures to confirm that the modification or changes produce expected :
results. These tests also demonstrate that the change does not produce an unsafe !
operating condition.
4.0 REFERENCES
The following references were used in the generation of this Section. The Company's commitment to particular revisions of these standards is contained in Section 2.
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ANSI N18.7 ANSI N45.2 ANSI /ASME NOA-1 ASME Code Section Ill, NCA-4000 ANSI N45.2.5 ANSI N45.2.13 Page 11-12 REVISION XX XIXX/99 I
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CONTROL OF MEASURIND AND TEST EQUIPMENT SECTION 12 l .
l 4. REFERENCES l
The following references were used in the generation of this Section. The Company's commitment to particular revisions of these standards is contained in Section 2.
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10CFR50 Appendix B l ANSI /ASME NQA-1 !
ASME Code Section Ill, NCA 4000 i
i Page 124 REVISION XX XIXX/99
HANDLIN9, STORAGE AND SHIPPING SECTION 13
- 4. REFERENCES The following references were used in the generation of this Section. The Company's commitment to particular revisions of these standards is contained in Section 2.
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10CFR50 Appendix B ANSI N18.7 ANSI N45.~2 ANSI /ASME NQA-1 ASME Code Section ill, NCA-4000 ANSI N45.2.2 ANSI N45.2.4 Page 13-3 REVISION XX XIXX/99
e . INSPECTION, TEST AND OPERATING STATUS SECTION 14 3.2.4' Return to Service When equipment is ready to be returned to sendoe, operating personnel place the equipment in operation and verify and document its functional acceptability. The Company assures return to normal conditions including:
- a. Removal of electricaljumpers.
- b. Removal of signals used during tos' ting.
- c. Returning valves, breakers, or switches to proper start-up or operating '
positions.
- d. Assuring that all alarms which are indicative of inoperative status are cleared.
A second qualified person verifies proper alignment of equipment unless: !
i
- a. All equipment, valves and switches involved in the activity can be proven to be in their correct alignment by functional testing without adversely affecting the safety of the plant, or
- b. Such verification would result in significant radiation exposure.
The person who performs independent verifications is qualified to perform such tasks.
When placed into service, equipment receives additional surveillance during the run-in period. The on. duty supervisor responsible for the unit formally accepts equipment which is returned to service.
- 4. REFERENCES The following references were used in the generation of this Section. The Company's commitment to particular revisions of these . standards is contained in Section 2.-
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ANSI N18.7 ANSI N45.2 ANSI /ASME NOA-1 ASME Code Section lit, NCA-4000 ANSI N45.2.13 Page 14 4 REVISION XX X/XX/99
, t . NONCONFORMIN3 MATERIALS, PARTS OR COMPONENTS SECTION 15 Nonconformances to design requirements that are dispositioned as "use-as-is" or
" repair are subject to design control measures commensurate with those applied to the original design. The Company technically justifies dispositions designated "as-is," to assure that the final condition of any n0000idunning item meets ASME Code requirements and will not adversely a3ect the safety, operability, or maintainability of the item, or of the conwient or system in which it is installed. The as-built records, if such records are required, reflect the accepted deviation.
if the nonconformance can be corrected after installation, the item may be released for installation on a conditional release basis. The Company documents the authority and technical justification for the conditional release of the item for installation and makes it part of the documentation.
3.4.5 Repaired, Reworked, or Scrapped items The Company reexamines repaired or reworked items using procedures and the original acceptance criteria unless the disposition has established alternate acceptance criteria.
.The Company reinspects items that have been corrected. The area of inspection may be confined to the area of the nonconformance. When it has been determined that the corrected item is satisfactory, the Company changes the status of the item to
" acceptable." The Company makes an appropriate entry in the documentation after acceptance is determined.-
The Company scraps, discards or transfers to training usage a nonconforming item that cannot be corrected or accepted "as-is". .
. 4. REFERENCES The following references were used in the generation of this Section. The Company's commitment to particular revisions of these standards is contained in Section 2.-
-in * 'b!e 3 0' th!: Sed!^ : e co-te! ed 5tM O.A P-~;= :09 ^ree.
10CFR50 Appendix B ANSI N45.2.13 ANSI N18.7 ANSI /ANS 3.2 ANS 3.2 ANSI N45.2.4 ANSI N45.2 - lEEE STD 336 ANSI /ASME NQA-1 ANSI N45.2.8 ASME Code Section lil, NCA-4000 ANSI N45.2.2 Page 154 R6 VISION XX XIXX/99
CORRECTNE ACTION SECTION 16
- 4. REFERENCES The following references were used in the generation of this Section. The Company's commitment to particular revisions of these standards is contained in Section 2.
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ANS 3.2 ANSI N45.2 ANSI /ASME NQA-1 ASME Code Section lil, NCA-4000 ANSI N45.2.13 ANSI /ANS 3.2 ANSI N45.2.11 Page 16-6 REVISION XX' X/XX/99
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QUALITY ASSURANCE RECORDS SECTION 17 3.s Storage Record storage facilities are established to meet regulatory requirements, including those of NQA-1, Supplement 17S-1 and ASME Code Section ill, NCA 4134.17.
, Storage systems provide for:
Assignment of responsibilities.
a.
- b. Control and accountability of records removed. .
3.6 Preservation in order to prevent deterioration, records are stored:
- a. In a manner to prevent damage from moisture, temperature, pressure, etc.
- b. In binders, folders, envelopes, or similar systems.
Manufacturers recommendations are followed for special recording media.
3.7 Safekeeping .
Measures are established to prevent access to records by unauthorized personnel.
These measures guard against theft and vandalism.
3.8 Retention Record retention periods are established to meet regulatory requirements. The most stringent retention period is implemented when multiple requirements exist.
3.9 Disposition Records will be dispositioned at the end of the prescribed retention period. A review of regulatory requirements will be performed prior to disposition to assure current requirements are satisfied. .
3.10 Plant Operating Records NOTE: The requirements contained in the articles and sub-articles of 3.10.1 and 3.10.2 apply to Braidwood, Byron, Dresden and Quad Cities, =d Zb stations. l The requirements were transferred here from the Braidwood, Byron, Dresden, and Quad Citie , W ZM Technical Specifications to meet administrative l commitments resulting from the Technical Specification Upgrade and improvement Programs. Similar requirements exist for LaSalle. Refer to the most recently approved amendment of LaSalle's Technical Specifications for applicable requirements.
Page 17-3 REVISION XX XIXX/99
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QUALITY ASSURANCE RECORDS SECTION 17 I
3.10.1 Records and/or Logs,5 Year Rotentien l Records and/or logs relative to the following items shall be kept in a manner convenient for review and shall be retained for at least 5 years:
- a. Records of normal plant operation, including power levels and periods of !
operation at each power level. !
i l
- b. Records of principal maintenance activities, including inspection and repair, (and replacement, for Braidwood and Byron) regarding principal items of equipment pertaining to nuclear safety. j
- c. Records and reports of reportable events.
- d. Records and periodic checks, inspection and/or calibrations performed to verify that the surveillance requirements of the Technical Specifications are ,
being met. All equipment failing to meet surveillance requirements and the I corrective action taken shall be recorded. ;
- e. Records of changes made to the equipment or reviews of tests and experiments to comply with 10CFR50.59. (Dresden and Quad Cities) ;
- f. Records of radioactive shipments.
- g. Records of physics tests and other tests pertaining to nuclear safety.
- h. Records of changes to procedures required by a station's Technical Specifications and other procedures which affect nuclear safety, as determined by the Station Manager or Plant General Manager,
- i. Shift Manager / Engineers' logs. i J. By-product material inventory records and source leak test results. (Dresden !
and Quad Cities)
- k. By-product materialinventory records and records of sealed source and l fission detector leak tests and results. (Braidwood and Byron-and-Zion) ;
i Page 17-4 REVISION XX X/XX/99
m
.w .
QUALITY ASSURANCE RECORDS SECTION 17 3.10.2 Records and/or logs, Lifetime Retention Records and/or logs relative to the following items shall be recorded in a manner convenient for review and shall be retained for the life of the plant:
- a. Substitution or replacement of principal items of equipment pertaining to nuclear safety,
- b. Changes made to the plant as it is described in the Safety Analysis Report.
- c. Records of new and spent fuel inventory and assembly histories (and fuel transfers for Braidwood and Byron).
i
- d. Updated, corrected, and as-built drawings of the plant. j l
- e. Records of plant radiation and contamination surveys. ]
- f. Records of offsite environmental monitoring surveys.
- g. Records of radiation exposure for all plant personnel, including all contractors and visitors to the plant, in accordance with 10CFR20. !
- h. Records of radioactivity in liquid and gateous wastes released to the environment. j
- i. Records of transient or operational cycling for those components that have j been designed to operate safely for a limited number of transient or ;
operational cycles.
J. Records of individual staff members indicating qualifications, experience, training, and retraining. ,
l
- k. Inservice inspections of the reactor coolant system. (Dresden and
. Quad Cities)
- 1. Minutes of meetings and results of reviews performed by the Nuclear Safety Review Board and the Plant Operations Review Committee. i
- m. Records for Environmental Qualification which are covered under the provisions of the station's Technical Specifications.
- n. Inservice inspections and testing performed pursuant to the Technical Specifications. (Braidwood and Byron =^d Zicr.) l Page 17-5 REVISION XX XIXX/99
7 QUAUTY ASSURANCE RECORDS SECTION 17 I
i 1
- o. Records of secondary water sampling and water quality. (Braidwood and !
l . ByronZion)
- p. Records of the service lives of all snubbers covered by Zi= UFSN',
T6'e 1S.? Si the Braidwood's and Byron's Augmented inservice Snubber inspection Program including the date at which the service life commences and associated installation and maintenance records. (Braidwood.grg Byron and4 ion)
- q. Records of reviews performed for changes made to procedures or equipment or reviews of tests and experiments pursuant to 10CFR50.59. (Braidwood !
l BDiByron und,Z4en)
- r. Records of Quality Assurance activities required by the QA Manual to be l
'l maintained as lifetime records. (Braidwood BDiByron and4 ion) l s. Records of reactor tests and experiments. (Braidwood ag.1 Byron and4ien)
- t. Records of reviews performed for changes made to the Offsite Dose Calculation Manual and the Process Control Program. (Braidwood 30.1 Byron l andaion) 1
- u. Records of analyses required by the Radiological Environmental Monitoring Program that would permit evaluation of the accuracy of the analysis at a 1 later date. This should include procedures effective at specified times and QA records showing that these procedures were followed. (Braidwood and ,
Byron) j
- 4. REFERENCES The following references were used in the generation of this Section. The Company's commitment to particular revisions of these standards is contained in Section 2.- !
S;:25c re'rm:r fr N re';9==t: !!:ted in Ad.!c'c 3 of thi: Ed!= =c ceti^d.
in 5 O.A Pregr= 0-*+r- .
1 ANSI /ASME NQA-1 10CFR50 Appendix B ASME Code Section lil, NCA 4000 ANSI N18.7 ANS 3.2 Page 17-6 REVISION XX X/XX/99
w AUDITS SECTION 18 Verification of the completion of scheduled corrective action commitments is performed to assure deficiencies or adverse conditions are corrected. Previous deficient areas or adverse conditions are followed up upon to assure corrective action is effective and implementation cont'mues.
3.1.7 Records The audit plan, report, objective evidence, written replies, and the record for deficiency follow-up and the completion of corrective action are on file. Personnel qualification records for audit team members are established, maintained, and reviewed.
3.2_ independent Management Audit / Assessment Audits of the Company are performed by the Authorized Inspection Agency as required by the ASME Code and ASME N626.0. A periodic review of the audit program is performed by an independent organization to assure that audits are being scccirplished to program requirements. An annual report on the status, adequacy, and implementation of the Quality Assurance Program is submitted to the President and Chief Nuclear Officer by the Nuclear Oversight Manager.
- 4. REFERENCES .
The following references were used in the generation of this Section. The Company's commitment to particular revisions of these standards is contained in Section 2.
S;::"i d:=r f= tM mMW: !!&d 5 Adb!? 3 o' th!: Erd!^ re ccate!aed b O.A. P~g r D-'-'rr.
10CFR50 Appendix B ANSI /ASME NQA-1 ASME Code Section lil, NCA-4000
. ANSI N18.7-1977 ANSI /ANS 3.2-1988 l
l l
l i
Page 18-5 REVISION XX X/XX/99
n.
4 o o AUGMENTED QUALITY SECTION 19
- 1. POLICY. l i
it is Comed's policy to assure a h:gh degree of availability and reliability for its nuclear plants while ensuring the health and safety of the public and its workers. Therefore, the Quality Assurance Program is applied in a graded manner to certain areas and activities that are not clearly defined as safety related or ASME Code related. The Company calls this application Augmented Quality.
- 2. RESPONSIBILITIES The following organizations are responsible for carrying out the requirements of this Section:
Nuclear Generation Nuclear Stations Site Material Management Site Engineering ;
Nuclear Engineering Services l Corporate Security Nuclear Support Organizations i Nuclear Oversight i TWpany cesigns-responsMties-for-specific-requrements4hrougMhe-Quality Assurance-Database-
- 3. REQUIREMENTS i
l The Company applies the Quality Assurance Program to certain systems, structures, components, and activities that are not safety related or ASME Code related to a i degree consistent with their importance to safety.
At Zion Nuclear Power Station (ZNPSL in its permanently defueled condition. there are no lonaer any structures. systems or components that are classified safety related. The cuality reauirements that are to be applied to structures, systems. components and activities at ZNPS are defined in Section 7 of the Zion Station Defueled Safety Analysis Report.
While there may be minor interfaces with additional sections of this manual, the j following sections apply to the programmatic elements of the noted activities:
Page 19-1 REVISION XX X/XIXX
,',., AUNMENTED QUALITY SECTION 19 Repairs and alterations performed as described above meet the requirements of the approved QA Program and meet the requirements of the IDNS B&PV rules; regardless of the safety classification of the boiler or pressure vessel or pressure relief valve being repaired.
- 4. REFERENCES The following references were used in the generation of this Section. The Company's commitment to particular revisions of these standards is contained in Section 2.
Speedio+eferences fe' the require =nt !!:ted !n Adicte 3 0' thi: Section ere contained in4he QA Pr~g'= De'92:0.
. 10CFR21
. 10CFR73
. ANSI /ASME NOA-2 e 10CFR50.47
. 10CFR26 Page 19 4 REVISION XX XIX/XX
g; .
nv NUCLEAR SAFETY REVIEW COARDS SECTION 20A 4
4 3.4 NSRB Review Responsibilities The NSRB shall review each of the subjects listed below. - A separate group, under
'.the auspices of the NSRB and independent of the organization responsible for the
- subject to be reviewed, may perform these reviews and report the results of its reviews to the NSRB. This group may also recommend full NSRB review of any subject as appropriate.
3.4.1 Written safety evaluations for (a) changes to procedures, equipment or systems and (b) tests or experiments completed under the provision of 10CFR50.59, to verify that such actions did not constitute an unreviewed safety question.
3.4.2 Proposed changes to procedures, equipment, or systems that involve an unreviewed safety question as defined in 10CFR50.59; l
3.4.3 Proposed tests or experiments that involve an unreviewed safety question as
. defined in 10CFR50.59;
' 3.4.4 Proposed changes to Technical Specifications or NRC operating license; 3.'4.5 All reportable events, per 10CFR50.73; 3.4.6 Responses to violations of applicable codes, regulations, orders, technical specifications, license requirements, or internal procedures or instructions having nuclear safety significance; 3.4.7 - Significant operating abnormalities or deviation from normal and expected performance of station equipment that affects nuclear safety; 3.4.8 All recognized indications of an unanticipated deficiency in some aspect of design or operation of safety-related structures, systems, or components; 3.4.9 A!! che ge: to the Gene'etiag S'et!On: Emergency Plan p'!Or to imp!:mentet!On of euch ch=nge^11 chances to the Generatina Stations Emeroency Plan. Those chanaes that reauire prior NRC aoorovat in accordance with 10CFR50.54(a) will be reviewed orior to implementation of the chanae.
3.4.10 All_ items referred by the Site Vice President; the Station Manager / Plant General Manager; the PORC Chairperson or the Nuclear Oversight Vice
' President.
.3.4.11 Safety Limit Reports (Braidwood and Byron) i
- Page 20A-3. REVISION XX XIXX/99
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l 1