ML20195C035
| ML20195C035 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 10/21/1988 |
| From: | Shelton D TOLEDO EDISON CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| 1604, NUDOCS 8811020304 | |
| Download: ML20195C035 (9) | |
Text
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TOLEDO
. EDISON 4 c-wa oww ome, c
DONALD C. SHEL10N Docket No. 50-346
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License No. NPF-3 Serial No. 1604 October 21, 1988 United States Nuclear Regulatory Commission Document Control Desk Vashington, D. C.
20555 Subj ect: Reorganization of Davis-Besse Engineering Assurance from the Quality Assurance Department to the Engineering Department Gentlemen:
In accordance with 10CFR50.54(a)(3), Toledo Edison Company hereby submits its plans regarding the Engineering Assurance (EA) function at Davis-Besse Nuclear Power Station, Unit No. 1.
The Engineering Assurance organization, reporting to the Quality Assurance Director, was expanded as part of the Davis-Besse Course of Action following the June 9, 1985 loss of feedvater incident to provide a quality review of the engineering activities on a day-to-day basis. To intensify the overvlev of engineering and design activities and to maintain accountability within Engineering for these activities, review of specified engineering ptoducts vill be transferred to a new Engineering Assurance (EA) Section within the Engineering Department. The new EA organization vill report directly to the Engineering Director and vill function independently of engineering line activities.
The new EA organization vill assume the quality review of procurement documents, specifications and modification packages. The Quality Assurance Department retains complete responsibility for quality assurance program auditing, surveillance and qualification of vendors.
Engineering Assurance activities vill be subject to audit by the Quality Assurance Department.
! provides a mark up of the proposed changes to affected sections of the Davis-Besse Updated Safety Analysis Report (USAR). These changes vill l
be incorporated in the next annual update of the USAR subsequent to NRC approval.
1 A quality assurance program as described by Criterion I of 10CPR50 Appendix B, I
is comprised of "... both the performing functions of attaining quality objectives and the quality assurance functions." The reorganization of l
Engineering Assurance does not impact the assignment of quality assurance functions, as defined by Criterion I (i.e. Assuring QA program establishment THE TOLEDO EDSON COMPANY EDSON PLAZA 300 MADSON AVENUE TOLEDO. OH:043652 GG11020304 891021 O
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Dotket No. 50-346 License No. NPF-3 Serial No. 1604 Page 2 and execution, auditing and inspection), which remain with the Quality Assurance Department. The reorganization does impact Engineering Department frinctions of attaining quality objectivos by providing a means to monitor its own performance and make necessary corrections.
The organizational change is consistent with ANSI /ANS-3.2-1982, Section 3.3 which states in part, quality assurance should be recognized as an interdisciplinary responsibility involving many organizational components and, therefore, shall not be regarded as the sole domain of a single quality assurance group." Based on the foregoing, it is determined that the reorganization has no adverse effect on the quality assurance program and its conformance to 10CFR50, Appendix B.
Toledo Edison intends to make the organizational realignment of Engineering Assurance by December 1, 1988. The cocpany requests the NRC to expedite its review and approval of the proposed change to support this schedule.
If you have any questions regarding this proposal, please contact Mr. R. V.
Schrauder, Nuclear Licensing Manager at (419) 249-2366.
Very truly yours,
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f KLB/dlm Attachment cc P. Byron, DB-1 NRC Resident Inspector A. V. DeAgazio, DB-1 NRC Senior Project Manager A. B. Davis, Regional Administrator, NRC Region III M. P. Phillips, Chief Operational Programs Section, NRC Region III t
Attachment I Page 1 D(LE ~ 5 SECT /OW
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QUALITY CONTROL MANAGER. The Quality Control Manager is responsible for managing the Quality Control Staff in the quality review, inspection, and examination of Q, Fire Protection, ASME Code, and selected balance of plant. structures, systems, and components to assure compliance to procedural drawing, and engineering specification requirements.
This responsibility includes the inspection of welding to verify it meets ASME, National Board, and State of Ohio requirements in.sddition to coordinating the activities of Authorized Inspection Agency to ensure Code compliance.
QUALITY VERIFICATION MANAGER.
The Quality Verification Manager reports directly to the Quality Assurance Director and is responsible for managing the Quality Verification staff in the performance of internal and selected external QA audits, and for QA surveillance of station operations.
> -ENGMEERMr-AS6URANGE-MANAGER.
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13.1.2.3 Planning and Support Department l8 Planning and Support Director reports to the Vice President, Nuclear and is responsible for directing the overall site planning, budgeting, cost control, and information management functions including those activities 8
in support of these functions:
cost and budget control, outage management, project managemen'., facility modification, computer systems, document and records management, systems and procedures and long range planning.
MAINTENANCE AND OUTAGE MANAGEMENT MANAGER.
Manages planning and scheduling 18 functions for all maintenance and modification activitiec for the Station.
During outage situations, directs the activities of participating organizations to ensure timely execution of Outage Plan.
TECHNICAL PLANNING MANAGER.
Manages Technical Support functions for l8 corrective actions and resolutions of plant deficiencies / deviations.
Manages planning and management efforts as they relate to the plant life cycle programs.
Also manages the maintenance of the Davis-Besse Surveillance Test Program, which includes, but is not limite,. to, review of Technical Specifications and the monitoring of all aspects of the program to ensure all program requirements are met.
FACILITY MODIFICATION MANAGER.
Manages plant modification and construction l8 of facilities and assigned contracted major activities in support of Davis-Besse Station.
Manages the construction program to ensure that material, services and cost estimates are provided to support construction schedules and budgets.
Manages and approves actions of the Modification Supervisors.
13.1-3 REV u 10/88-f& 4~<rp h t$IM ]
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INTEGRATED PI.ANNIf.G MANAGER. Manages the integration of planning and l8 s:heduli.1g functions as they relate to Engineering, Modifications and Long Range Planning in support of Nuclear Group Goals and Objectives. Also, manages the allocation of Davis-Besse's key resources to meet management's l
internal and external commitments.
INFORMATION MANAGEMENT MANAGER. Provides operating support services to the 8
l Nuclear Group in the areas of Records Management, Documentation Systems and l
Computer Systems Management. Also assures that site systems and procedures and developed and implemented in accordance with established Group Policies l
and Procedures.
l 13.1.2.4 Engineering Department l8 ENGINEERING DIRECTOR. Responsible for all nuclear engineering activity l8 in support of design control, plant modifications, and system performance requirements. The Engineering Director reports to the Vice President, l8 i
Nuclear.
DESIGN ENGINEERING MANAGER. Manages engiueering activities relating to l8 facility additions or modification of the Davis-Besse Station and provides non-routine engineering support services to assist Plant personnel in the evaluation and resolution of operation and maintenance problems.
Provides support to other Nuclear Group Departments requiring engineering assistance.
l8 Assures that Davis-Besse facilities are designed in accordance with good engineering practice and meet applicable codes, standards, and regulations.
Also responsible for proper control of design and design basis documents.
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[ENGINEERINGASSURANCEMANAGER f
The Engineering Assurance Manager reports directly to the Engineering Director and is responsible for managing the Engineering Assurance Section in the review of engineering activities on a day to day basis.
l These activities include review of procurement documents, engineering
- g specifications, and monitoring of work packages to assure that appropriate quality requirements are being specified and adhered to in the design and procurement process.
He is also responsible for t
l participating in the development of procedures governing engineering crh t: ensure their adequacy, and for condti..t of i -hp h uchnical evaluations to assess the technical adequacy of engineering products.
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QUALITY VERIFICATION MANAGER The Quality Verification Manager reports directly to the Quality Assurance Director and is responsible for managing the Quality Verification staff in the performance of internal and selected external QA audits, and for QA sutveillance of station operations.
QUALITY SYSTEMS MANAGER The Quality Systems Manager reports directly to the Quality Assurance Director and is responsible for supervising the Quality Systems Staff.+n--
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(#cxr o g PA G G / 7.2 -8 N ENGINEERING DIRECTOR l3 The Engineering Director reports directly to the Vice President, Nuclear, 18 and is responsible for all Toledo Edison and contracted engineering activity in support oi design control, plant modifications, and system
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<> performance requirements for the Davis-Besse Nuclear Power Station.
l-ENGINEERING PROGRAMS MANAGER 18 The Engineering Programs Manager reports to the Engineering Director 18 and is responsible for providing management direction for Engineerin-Programs which are vital for required improverents of operations of Davis-Besse.
These programs include Engineering, ^=lity Impr=cacr.tv 18 f 9 and a Chemistry / Radiochemistry Improvement program."
NUCLEAR ENGINEERING MANAGER l8 The Nuclear Engineering Manager reports to the Engineering Director and is l8 responsible for managing and coordinating department functions relating to reliability and risk assessment, nuclear reactor analysis, nuclear safety analysis, simulator engineering, and industrial projects.
DESIGN ENGINEERING MANAGER l8 The Design Engineering Manager reports to the Engineering Director and is 18 responsible for directing and managing the performance of engineer-ing, safety evaluations, and accident analyses relative to modifications for Davis-Besse to assure optimum safety.. availability, and reliability.
He also provides engineering support to address non-routine technical issues related to the operation and maintenance of Davis-Besse.
SYSTEMS ENGINEERING MANAGER 18 The System Engineering Manager reports to the Engineering Director 18 and is responsible for minimizing Davis-Besse forced outage and lost capacity by providing systems engineering services to ensure proper installation, operation, maintenance, testing, and problem resolution for optimum system performance and reliability.
PERFORMANCE ENGINEERING MANAGER 18 The Performance Engineering Manager reports to the Engineering Director 18 and is responsible for directing the activities of the Performance Engineering Section to provide direct day-to-day engineering support in the areas of plant thermal performance monitoring, inservice inspection and testing, plant computer systems performance, reactor refueling, core physics testing and operations, fuel performance, plant operations assessment, modification testing and special testing, preventive / predictive maintenance, transient assessment and review of all external information (INPO, NOMIS, Network) in support of improved performance and reliability and special engineering projects.
FIRE PROTECTION CCMPLIANCE SUPERVISOR The Fire Protection Compliance Supervisor reports to the Engineering Director and is responsible for the formulation, implementation, and periodical asses-3 sment of the effective. ness of the Fire Protection Program.
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be performed under the most adverse design conditions as determined by analysis.
When alternate calculations are performed to verify the correctness of the original calculations, they include provisions for verifying the appropriateness of assumptions, input data, and code or other calculation method used. The alternate method when used is required to provide results which are censistent with the original calculation or analysis.
17.2.3.5 Design Packace Review Prior to release, the completed design package is reviewed by Nuclear Group Departments affected by the design. All review comments are document-l8 ed and resolved, and in addition, analyzed for potential impact on safety q
evaluations and design verifications.
Gelected-detailed-desivewpackages-ce :eviewed by qu:lity-Asawanee, including :::eciated deeign decurente te 2: ure th:1 spprepriate qu:lity accurance requirem:nt: cuch 2: inspectier :nd te:t requirement: :nd=
accept:ne: :quirement: 2r: included.
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wNetsed :: d:scrib:d in S::tien 17.2.16s 17.2.4 PROCUREMENT DOCUMENT CONTROL 17.2.4.1 General The procurement of materials, components, equipment, consumables, spare and replacement parts, services, etc., necensary for plant operation, refueling, maintenance, and modification are controlled in accordance with procedures established by Procurement, the Engineering Department, Opera-18 tions, Quality Assurance and Materials Management. These procedures specify measures that describe the procesa for the preparation and control of procurement documents, control of supplier and contractor performance, source evaluation and selection, source verification, receiving inspection and testing, and item or service acceptance.
The requirements of ANSI N45.2.13 and ANSI N45.2.2 are incorporated into their procedures whenever the requirements are applicable.
Expeditious procurement activities are defined in procedures to support unanticipated requirements.
These procedures contain provisions for material traceability and controls to prevent the declaration of operabil-ity of the system until such time that the activity and documentation requirements specified in the approved procurement document have b2en completed or evaluated by the Engineering Department for operability.
l8 The procurement of spare or replacement parts for structures, systems and components within the scope of the Nuclear Quality Assurance Program are subject to requirements equal to or greater than the original requirements.
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Acd to end of first paragraph:
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a "Design package development is also monitored on a day to day basis by the Engineering Assurance Section to ensure the adequacy of engineering i
documents released for implementation.
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Replace second paragraph with the following:
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"Selected design modifications, documented by one or more design l
packages, are subjected to design evaluations under the direction oi the Engineering Assurance Manager to assess the effectiveness of the design procest and the technical adequacy of design products.
Design e
evaluations are conducted by Enginecring Assurance Coction personnel supplemented as necessary by engineering personnel having technical expertise in the areas to be evaluated.
Participating engineering l.
personnel will not have responsibility for the design products to be evaluated, and their selection f rom within Toledo Edison or as
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f contractors, is approved by the Engineering Assurance Manager.
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addition to correcting identified deficiencies, significant or
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vecurring deficiencies are processed in accordance with Section 17.2.16.
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Identification of documents to be prepared, maintained, submitted, or made available for review and/or approval, such as drawings, I
specifications, procedures, sub-supplier procurement documents, manufacturing and inspection plans, inspection and test records, personnel and procedure qualifications, and material chemical and physical test results.
5 g.
Provisions for Toledo Edison's right-of-access to the suppliers' facilities and records for audits and source inspection.
h.
Requirement for reporting and approval for disposition of nonconform-ing items and adherence to 10CFR21 requirements.
Nuclear fuel is procured through the use of formal contracts signed by an officer of the Toledo Edison Company. An individual has been designated by the Plant Manager as the "Fuel Custodian" and acts in the capacity of the Procurement Manager for the procurement of nuclear luel.
l8 17.2.4.3 Procurement Document Review hPrc, curs.ent de;=;nt; are reae.;ec. and +r. m ed at e.aini..,_, W d.e zuv nuring :nd ^uclity-Ae:ur:n : Departments-pei+r-to-their =:rd t: r,.v ";;11-18 e Changes to the technical and quality requirements, including supplier selection, are subject to the same dr. gree of review as the original procurement document.
The review conducted by the Engineering Department is performed to establish l8 and assure that the technical and quality requirements are sufficient, clear and adequately stated: can be inspected and controlled and include adequate accept / reject criteria. These requirements include regulatory, achinistrative and reporting requirements: specifications; codes and industrial standards test and inspection requirements, and special process instructions that must be complied with by suppliers.
&~ye,i,1ceninos AtsuRnact Sarag, suo uutts MpuMaL6 The review conducted by the Quality Assurance Department is performed to 18 secure that quality requirements are sufficient, clear and adequately stated; inspectability requirements are satisfied; hold or witness points are adequate accept / reject criteria are included: the checklist prepared by the Engineering Department is included that describes the l8 characteristics to be inspected at receiving inspections and that the supplier is included on a listing of approved vendors.
17.2.4.4 Supplier selection Prior to award, potential suppliers are evaluated to determine their ability to supply items or services in accordance with the requirements of pro-curement documents. The evaluation also includes a technical evaluation, which may include direct evaluation of the suppliers' facilities and personnel as described in 17.2.7.
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