Text

Forwards Revised QA Program Description,Previously Submitted as Part of FSAR Rev 46 & Amend 82 to License Application
	ML20203M930
Person / Time
Site:	Limerick
Issue date:	04/23/1986
From:	Daltroff S; PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Murley T; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
	NUDOCS 8605020168
	Download: ML20203M930 (132)
	v • d • e

{{#Wiki_filter:- - ~ _ - - -.. 1 PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET P.O. BOX 8699 PHILADELPHI A. PA.19101 $HIELOS L. DALTROFF ELacTarc Pm o criom Docket Nos. 50-352 50-353 April 23, 1986 Dr. Thomas E. Murley, Administrator U.S. Nuclear Regulatory Commission 1 Region 1 i Office of Inspection and Enforcement 631 Park Avenue King of Prussia, PA 19406

SUBJECT:

QA Program Description Changes for Limerick Generating Station j t

Dear Dr. Murley:

i In accordance with section 50.54(a)(3) of the commission's Regulations, enclosed is the Philadelphia Electric Company revised Limerick Generating Station Quality Assurance Program Description. The enclosed revised description was previously transmitted to the Commission on March 31, 1986 as part of Revision 46 of the LGS Final Safety Analysis Report and Amendment i No. 82 to the License Application. Changes made to the Quality Assurance Program description previously accepted by the NRC are identified by a bar in the left hand margin. It has been determined that these changes to the QA Program description do not reduce the commitments in the previously accepted program description. For your information, we have enclosed a OA Program Change i Summary list. This list identifies the following for each change:

1) Page number, 2) Paragraph number, 3) Brief

~ description, and 4) Type of change. 8605020168 860423 i PDR ADOCK 05000352 l g p PDR , _.,..., _. _ _ ~.. _... _ -. _ _. - _ _. _ _.

. If you have any questions or comments on these changes, please contact Mr. D. L. Mcdonald at (215) 841-5414. Very truly yours, ) / / l.Y f ./(,,C d bl4 /' Vice President Electric Production Enclosures cc: E. M. Kelly Senior Resident Inspector Limerick Generating Station P. K. Eapen, Chief Quality Assurance Section Region 1 (w/o Enclosures) Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555 SEE ATTACHED SERVICE LIST RBW/sw

j l cc: Troy B. Conner, Jr., Esq. (w/o enclosure) Ann P. Hodgdon, Esq. (w/o enclosure) 4 Mr. Frank R. Romano (w/o enclosure) i Mr. Robert L. Anthony (w/o enclosure) Ms. Phyllis Zitzer (w/o enclosure) Charles W. Elliott, Esq. (w/o enclosure) Barry M. Hartman, Esq. (w/o enclosure) Mr. Thomas Gerusky (w/o enclosure) Director, Penna. Emergency (w/o enclosure) Management Agency Angus Love, Esq. (w/o enclosure) i David Wersan, Esq. (w/o enclosure) Robert J. Sugarman, Esq. (w/o enclosure) Kathryn S. Lewis, Esq. (w/o enclosure) Spence W. Perry, Esq. (w/o enclosure) Jay M. Gutierrez, Esq. (w/o enclosure) Atomic Safety 6 Licensing Appeal Board (w/o enclosure) 4 Atomic Safety 6 Licensing Board Panel (w/o enclosure) l Docket 6 Service Section (w/o enclosure) E. M. Kelly (w/o enclosure) Timothy R. S. Campbell (w/o enclosure) d i I i t

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LGS FSAR r e-s c-A } E.'i 5, ,h 17.2 OUALITY ASSURANCE DURING THE OP ATIONS1 PHASE'hfl} %s""~ hn r n ovI fGD Philadelphia Electric Compeny is responsible fo (gyri g that Limerick Generating Station (LGS) is operated, m Intained, and modified in accordance with applicable regulatory requirements. To ensure the quality of safety-related activities during the operations phase, Philadelphia Electric Company has established a management control plan which complies with 10CFR50, Appendix B. This plan consists of (1) the Electric Production Department Quality Assurance Program and the Engineering and Research Department Quality Assurance Program which contain Philadelphia Electric Company's quality assurance commitments to the Nuclear Regulatory Commission, (2) Quality Assurance Plans for each of the above departments which contain a description of policies and program elements to implement the commitments to the NRC, and (3) organizational unit procedures necessary for the unit to comply with the requirements of the QA Programs and Plans. The Electric Production Department Quality Assurance Program and the Engineering and Research Department Quality Assurance Program (T (,) are described in Section 17.2A and Section 17.2B respectively. These programs comply with the requirements of 10CFR50, Appendix B and are based on the recommendations of QA related NRC Regulatory Guides and associated Industry Standards. Compliance to these regulatory guides and standards is addressed in Appendices to Section 17.2A and Section 17.2B. 17.2.1 ORGANIZATION Tne Philadelphia Electric Company corporate structure is shown on the Executive Organization Chart (Figure 17.2-1). The 12 departments are directed by their Vice Presidents, who report to the Office of the Chief Executive. The following Departments are involved in Quality Assurance related activities for LGS: Nuclear Power, Electric Production, Engineering and Research, Purchasing & General Services, Legal, Personnel and Industrial Relations, and Finance and Accounting. 17.2.1.1 Office of the Chief Executive Tne Cnateman of the Board of D' rectors and Chief Executive Officer, and the President .J Chief Operating Officer comprise ( the Office of the Chief F.ecutive. The President of Philadelphia l l 17.2-1 Rev. 46, 03/86

LGS FSAR O Electric Company has the ultimate responsibility for the PECo Quality Assurance Program. The President delegates to the Vice President - Electric Production Department and the Vice President - Engineering and Research Department, the responsibilities for instituting and maintaining the Quality Assurance Programs. The Senior Vice President-Nuclear Power acts as the direct agent of executive management in implementing company policies relating to nuclear power and in ensuring their accomplishment. 17.2.1.2 Electric Production Department The organization of the Electric Production (EP) Department is shown in Figure 17.2-2. l 17.2.1.2.1 Vice President and Managers - EP Department The Department is under the direction of the Vice President - Electric Production, assisted by the Manager - Nuclear Production and the Managers - Fossil / Hydro Production. They are responsible for the operation, maintenance and modification of the Company's electric generation facilities and establishment and implementation of Electric Production Department Quality Assurance Program, goals, and objectives. l The Electric Production Department contains six Divisions: Fossil / Hydro Generation, Quality Assurance, Services. Nuclear Generation, Maintenance, and System Operation. The Electric Production Department is responsible for Quality Assurance in plant operation from the acceptance of each system from the Architect / Engineer (Startup Phase) through the life of the plant. The Department is supplied procurement services, engineering design services, and other support functions from other Philadelphia Electric Company Departments and contractors, as necessary. The Department is divided into functional units allowing centralization of expertise and economic operation. This centralization lends itself to quality assurance activities cince it provides checks and balances in varied fields by organizations that are administratively independent of each other. O 1 Rev. 46, 03/86 17.2-2

LGS FSAR 17.2.1.2.2 Nuclear Generation Division ~- n (" O The Nuclear Generation Division organization, _ dutfes', an' \\ d responsibilities are described in Sectiorpl3.1. . jg' 1 g,g - L b:[% ikyd(1,OL' 17.2.1.2.2.1 t y v The Station organization, duties, and respo ities are described in Section 13.1. 17.2.1.2.3 Quality Assurance Division The Quality Assurance Division (Figure 17.2-3) is responsible for administering the overall Quality Assurance Program of the Electric Production Department within the framework of corporate Quality Assurance Policy as set forth in the Introduction. The Division is headed by a Superintendent who reports directly [- 3l to the Manager - Nuclear Production. The Division is composed of four sections: Engineering, Audit, Quality Control, and Training. 17.2.1.2.3.1 Superintendent - Quality Assurance Division l Qualifications for the position of Superintendent - QA Division, are established by the Vice President - Electric Production Department based on recommendations of the Manager - Nuclear Production. At the time of appointment, the Superintendent shall have a bachelors degree or the equivalent in an engineering or science subject and shall have a minimum of 10 years of responsible administrative or operating experience in the Electric Production Department of which a minimum of 3 years shall be in the fields of power plant operation, maintenance, engineering, safety, and/or. quality assurance. A maximum of 4 years of the remaining 7 years of experience may be fulfilled by satisfactory completion of academic or related technical training on a one-for-one time basis. The Superintendent shall have a knowledge of OA regulations, policies, practices, and standards. The education and experience requirements specified should not be treated as absolute, as Management retains the right to evaluate () alternative experience and administrative training to qualify for (s/ this position. 17.2-3 Rev. 46, 03/86 t

LGS FSAR l The Superintendent - Quality Assurance Division has the following responsibilities and authorities: a. Formulate, develop, and establish Quality Assurance policy in the areas of operations, maintenance, modifications, in-service inspection, fuel /invessel material, radiological and environmental monitoring, fire protection, emergency preparedness, health physics and chemistry, radioactive waste / material, physical security, training, surveillance testing, procurement, audits, records, nonconformance and corrective action. b. Administration and coordination of the Electric Production Operations Quality Assurance Program (EP 00A Program). l c. Furnish overall direction for implementing the EP OOA Program. d. Review and approve Administrative procedures that implement the EP 00A Program. e. Approve all Quality Assurance Division Procedures and Audit Instructions for the implementation of the EP 00A Program. l f. Require verification of corrective action and problem resolution for items affecting quality, g. Initiate and recommend corrective action or provide solutions through designated channels. h. Direct immediate cessation of work when such work is considered by the Superintendent - Quality Assurance Division to be a serious quality degradation. This stop-work authority shall be delineated in applicable j i procedures. 1. Determine the ongoing status and adequacy of the EP OOA Program through regular review of the QA Division Auditing and Quality Control Programs, identification and investigation of problem areas, and determination of timely and effective steps taken to correct Rev. 46, 03/86 17.2-4 1

LGS FSAR deficiencies; and the evaluation of general plant QA/QC performance through such other inputs as are available or are deemed necessary to make a reasonably objective and confident judgment. j. Apprise the Manager --Nuclear Production, theWib President - Electric Production Department, hd't e Nuclear Review Board periodically of.the"st tus the Quality Assurance aspects of LGS, operation'and" immediately of significant p lemozaffecting quality. ws p

1.

k. Control contents and rev f Plan. l 1. Ensure that personnel involved in the implemention of the QA Division Procedures are trained and, as appropelate, qualified. m. Contract for QA/QC consulting services as necessary. n. To assess, through Quality Assurance Audits and 1 Surveillances, and Quality Control Monitoring and . Inspections, the adequacy and effectiveness of procurement documents, modification and maintenance procedures. i i To approve Audit and Surveillance reports and o. Noncompliance Reports (NCRs) and responses thereto. p. Delegation of portions of the Quality Assurance Program during the operational phase to the Engineering and Research Department QA Division (e.g., major modifications, Evaluated Suppliers List, Vendor Evaluations, etc.). [ q. Provide support for QA/QC training and qualification programs, as required for implementation and execution of the EP OOA Plan. i O 17.2-5 Rev. 46, 03/86

LGS FSAR O 17.2.1.2.3.2 Engineering Section The Engineering Section is under the direction of the Engineer - QA who reports to the Superintendent - Quality Assurance Division. The Engineer - QA is responsible for the following: l a. Prepr. - and maintain the EP OOA Plan and QA Division Procedures and Instructions. l b. Implement and document the EP OOA Plan, programs and procedures as applicable, c. Keep the Superintendent - Quality Assurance Division informed of status of Quality Assurance effort and of significant problem areas. d. Provide the technical direction of Quality Assurance activities of the Quality Assurance Division Engineering Staff. e. Maintain a liaison with the LGS Plant Staff, other PECO organizations, and outside companies in order to advise and direct quality assurance activities during plant operations and maintenance. f. Ensure, in conjunction with the General Supervisor - OC and General Supervisor - QA, that deficient areas which require corrective action, identified in audits, surveillances, monitoring, or inspections are included in re-audits, surveillances, monitoring, or inspections, as appropriate. l g. Issue audit and surveillance reports. h. Control the preparation and distribution of the EP OOA Plan and revisions thereto. i. Review the EP OOA Plan and the QA Division Procedures and Instructions if revisions are required. O Rev. 46, 03/86 17.2-6

LGS FSAR O V j. Maintain a controlled filing system of records pertaining to the QA Division's implementation of the EP OQA Plan. k. Maintain current codes, standards, and regulations pertaining to the EP OQA Program. ., n hh 1. Keep the Superintendent - Quality Assurance Div.la n advised on the status of regulationss' codes; arida standards which may effect the content of'the"EP OOA

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~ h% 17.2.1.2.3.2.1 QA Engineering Sect taff 'N' The Engineering Section Staff, under the direction of the Engineer - QA, shall provide the technical and administrative support requirements of the EP QA Division as assigned. 17.2.1.2.3.3 Audit Section The Audit Section is under the direction of the General Supervisor - QA, who reports to the Superintendent - Quality Assurance Division. The General Supervisor - QA has the following responsibilities: a. Provide administrative supervision and technical direction of the activities of the Quality Assurance Division Audit Section. b. Direct the performance of audits and surveillances in accordance with written procedures to ensure compliance with the EP OQA Plan. c. Oversee the preparation of Quality Assurance audit check lists. d. Consult with the Superintendent - Quality Assurance Division, General Supervisor - OC, and Engineer - QA on significant problems affecting quality. O e. Review results of audits and surveillances. l 17.2-7 Rev. 46, 03/86

LGS FSAR O f. Review with the Engineer - OA and General Supervisor - OC deficient areas identified by audits and surveillances. g. Ensure that items requiring corrective action, identified by the auditing program, are included in rescheduled audits and surveillances. h. Schedule and direct the planning of auditing program to l ensure compliance with the EP OOA Plan. i. Recommend to the Superintendent - Quality Assurance Division, the issuance of Noncompliance Reports as a result of reviews of the OA Division audits, surveillances, and other activities, j. Assure that personnel involved in performing OA audits and surveillances are trained and qualified. 17.2.1.2.3.3.1 Audit Section Supervisors j) Under the administration of the General Supervisor - OA, the Site and Corporate Audit Supervisors have the following responsibilities: Supervise and perfort the preparation, conduct, and reporting of audits and surveillances of Limerick Generating Station activities as required by regulations, Company policies, and OA Division procedures. 17.2.1.2.3.3.2 Audit Section Staff Under the direction of the Site or Corporate Audit Supervisor, the Audit Section Staff has the responsibility tot a. Conduct the auditing program in accordance with the OA Division Procedures and Instructions Manual to ensure compliance with the EP 00A Plan. b. Provide continuing awareness of plant condition.' and status of daily onsite activities in order to interm the Site or Corporate Audit Supervisor of plant activit10s affecting quality. Rev. 46, 03/86 17.2-8

LGS FSAR Prepare audit and surveillance checklists and reports. c. d. Identify problems ad.rerse to quality through the auditing program and notify management of the audited organization in accordance with applicable procedures. e. Recommend corrective action through designated channels. l f. Verify implementation of corrective action of problems adverse to quality. g. Verify compliance with quality-related procedures and instructions. h. Keep the Site or Corporate Audit Supervisor advised status of the Quality Assurance Program through the %. Division Auditing Program. p s n V\\\\ f,gg '\\ % :/ ConductindependentHydroandreseIf1ha kh for i. operations and maintenance ac iviti !affectin uality and reliability as required b ~ ' iiis K divisional management. h 17.2.1.2.3.4 Quality Control Section The Quality Control Section is under the direction of the General Supervisor - OC, who reports to the Superintendent - Quality Assurance. The General Supervisor - OC has the following responsibilities: Provide administrative supervision and technical a. direction for the activities of the Quality Assurance Division OC Inspection personnel. b. Oversee the inspection activities and monitoring program in the areas of receipt inspection, radwaste packaging and handling, Maintenance Division activities, Health Physics and plant operations, Housekeeping, etc., as appropriate. 17.2-9 Rev. 46, 03/86 l

LGS FSAR O c. Consult with the Superintendent - Quality Assurance Division, Engineer - OA, and General Supervisor - OA when significant problems affecting quality are identified. l d. Overview of the QC monitoring and inspection activities, schedules, and results. I Overall planning for the preparation of Quality Control e. Instructions (OCIs) f. Review of appropriate Maintenance procedures, Radwaste Shipping and Packaging, Health Physics procedures, and Startup Test Procedures for implementation of DC Witness and Verification Points. g. Ensure that the personnel involved in the implementation of the DC inspection activities are trained and qualified. h. Ensure that items requiring corrective action identified ~ in monitoring or inspection activities are included in rescheduled monitoring, inspections, audits, or surveillances, as appropriate, i. Recommend to the Superintendent - Quality Assurance Division, the issuance of Noncompliance Reports (NCRs) as a result of the DC Monitoring and Inspection Programs. j. Review procurement documents initiated by the Electric Production Department organizations for safety-related items and services to ensure that adequate quality requirements are included. 17.2.1.2.3.4.1 Site DC Supervisor Under the administration of the General Supervisor - OC, the Site DC Supervisor has the following responsibilities: supervise and perform the preparation, conduct, and reporting of OC Inspections and Monitoring of Plant Activities as required by regulations, l Company policies, and 0A Division Procedures. Rev. 46, 03/86 17.2-10

LGS FSAR O 17.2.1.2.3.4.2 QC Staff Under the direction of the Site QC Supervisor, the QC Staff (OC Engineers and Inspectors), have the responsibility to a. Perform receipt inspection for safety-related items and services procured by the Electric Production Department. _6(\\ b. Perform QC inspection and monitoring of radwest'e J

\\Syp handling, packaging, and shipping..,

g;[ \\' _y PerformQCinspectionofsafe/N'ehated Lpment c. maintenance. TN ^ %> "g(lQ g d. Perform QC inspection and monitoring VI refueling operations. e. Perform QC inspection of minor modifications performed O by the Electric Production Department. f. As appropriate, perform QC inspection and monitoring of lifting and handling of heavy loads and safety-related components. g. Monitor day-to-day activities of plant operations. h. Perform receipt inspection of new fuel, i. Review procurement documents initiated by Electric Production Department organizations for safety-related equipment and services to ensure that adequate quality requirements are included. 17.2.1.2.3.5 QA Training Section The Training Section is under the direction of the Training Coordinator who reports to the Superintendent - Quality Assurance rQ Division. The Training Coordinator has the following G' responsibilities: 17.2-11 Rev. 46, 03/86 l

LGS FSAR a. Develop and maintain a Quality Assurance indoctrination and training program for the various employee position levels within the Electric Production Depaetment. b. Develop and maintain a Quality Assurance Training Program for qualifying, certifying, and requalifying QA Division personnel including: QA Engineers, QA Auditors, QA Assistants, QC Engineers, OC Inspectors, and QC Technicians. c. Develop QA/QC training programs for EP QA Division functional areas of responsibility. d. Evaluate training requirements for QA/QC personnel and prepare training program outlines, courses, and modules, e. Evaluate proposed courses, seminars, and training alternatives against training programs to ensure that training offered will meet the training objectives. f. Develop, document, and maintain QA training records for QA Division personnel as necessary to meet QA program commitments. 17.2.1.2.4 Services Division The Services Division is under the supervision of a Superintendent who reports to the Manager - Fossil / Hydro Production. The Division is composed of the Chemistry Section, the Costs Section, and the Computer Applications Section, and has responsibility for administrative and engineering support for the Electric Production Department. 17.2.1.2.4.1 The Chemistry Section, under the direction of the Chief Chemist, who reports to the Superintendent, Services Division, is l responsible for assisting the plant staff in the performance of routine and special tests and analysis of a chemical nature. O Rev. 46, 03/86 17.2-12

i I LGS FSAR >O i V 17.2.1.2.4.2 l The Costs Section under the direction of the Engineer-in-Charge, who reports to the Superintendent, Services Division, is responsible for the function of Electric Productfon Dep/artment budgeting, cost tracking, and cost analysis. ef', n s 4 74 o Q,.. g(. q v y 3 17.2.1.2.4.3 l The Computer Applications Secti ' is und Supervision of an Engineer-in-Charge, who reports to the Su ntendent, Services Division. The section is responsible for maintenance and modification of software for existing computer installations within the Electric Production Department and software design for t l new installations. 17.2.1.2.5 Maintenance Division l l <~w The Maintenance Division (Figure 17.2-4), under the supervision g (,j of a Superintendent who reports to the Manager - Fossil / Hydro i Production, is responsible for the Maintenance activities at all generating stations and steam heating plants. The Division is composed of three sections and one branch: Station, Mechanical, and Electrical Sections and a Services Branch. Maintenance activities at LGS are performed under the cognizance of the LGS Maintenance Engineer and a Maintenance Division Supervising Engineer assigned to the site. 17.2.1.2.5.1 Station Section i The Station Section, under the direction of a Superintendent, consists of qualified craftsmen, supervision, and technical personnel to carry out maintenance functions at the generating stations. An LGS Maintenance Group, under the direction of a Site Supervising Engineer and a Maintenance Supervisor, coordinates Maintenance Division activities at the Station. This Group consists of qualified craftsmen and supervision as necessary to carry out routine maintenance functions at the station. l The Maintenance Foremen at LGS report to the Maintenance Supervisor and are responsible for planning and supervising l l 17.2-13 Rev. 46, 03/86

LGS FSAR O maintenance programs which are originated through the LGS Maintenance Engineer. The Maintenance Technical Support Group at LGS is under the supervision of an Engineer-Supervisor and is assigned full time to the LGS Site. This group is responsible for technical support of OA-related Maintenance activities. One or more members of this group shall be designated to provide technical assistance and engineering support to LGS Maintenance personnel. The interface between station maintenance forces, the operating staff, and maintenance headquarters is shown on Figure 17.2-5. 17.2.1.2.5.2 Electrical Section The Elect.rical Section, under the direction of a Superintendent, is responsible for the inspection and maintenance of electrical equipment and components. The Electrical Section performs the above functions, as necessary, to support the Limerick Maintenance Group. O 17.2.1.2.5.3 Mechanical Section The Mechanical Section, under the direction of a Superintendent, consists of qualified craftsmen and supervision who support maintenance functions at LGS. The Mechanical Section is divided into seven groups: Mobile Turbine Group, Hobile Boiler Group, Service Group, Oregon Shop, Balance Group, In-service Inspection (ISI) Group, and Technical Support Group. These groups report to a supervisor or a supervising engineer who in turn reports to the superintendent. The organization and . interface between these groups are shown on Figure 17.2-4. 17.2.1.2.5.3.1 Mobile Turbine Group The Mobile Turbine Group is under the supervision of a foreman. This group consists of sufficient and qualified craftsmen and supervision to perform maintenance on turbine equipment. O Rev. 46, 03/86 17.2-14

LGS FSAR O 17.2.1.2.5.3.2 Mobile Boiler Group ,s 89 .1 y, The Mobile Boiler Group is under the supervision-of a foreman. This group consists of sufficient and qualif.ied~ craftsmen and supervision to perform maintenance on au k11ary" boilers and " \\ja7.,}N various iron-work projects. .iC.3 f 17.2.1.2.5.3.3 Service Group The Service Group is under the supervision of a foreman. This group consists of sufficient and qualified craftsmen and supervision to perform maintenance service to support other maintenance activities. This service consists of, but is not limited to, scaffold erection and disassembly, insulation removal, and reinsulation. 17.2.1.2.5.3.4 Oregon Shop The Oregon Shop is under the supervision of a foreman. This group consists of sufficient and qualified craftsmen and supervision to perform offsite machine shop fabrications and repairs. 17.2.1.2.5.3.5 Balance Group The Balance Group is under the supervision of a foreman. This group consists of sufficient and qualified craftsmen and supervision to perform vibration analysis and determine the requirements for balancing rotating equipment. 17.2.1.2.5.3.6 In-service Inspection Group The In-service Inspection Group is under the supervision of an Engineer-Supervisor. This group consists of sufficient and qualified craftsmen and supervision responsible for directing, controlling, and coordinating NDE activities performed in accordance with the ASME B&PV Code, Section XI. All NDE inspectors are qualified to ASNT-TC-1A as specified in Section 17.2A.9. There are also an assistant foreman and a subforeman, under the supervision of the Engineer-Supervisor, who have the (~3 responsibility for crane inspections. L/ 17.2-15 Rev. 46, 03/86

LGS FSAR 17.2.1.2.5.3.7 Technical Support Group The Technical Support Group is under the supervision of a Supervisory Engineer. This Group provides technical and engineering support to the other groups in the Mechanical Section. l 17.2.1.2.5.4 Services Branch The Services Branch, under the direction of a Supervising Engineer, consists of the Administrative Services Group, Engineering Group, Field Services Group, and Training and Testing Group. The Administrative Services Group supports the maintenance clerical and personnel function. The Field Services Group investigates safety concerns and schedules the proper classes and awareness training necessary for the employee to work in a safe manner throughout the system. The Training and Testing Group provides for the training of helpers and craftsmen and qualification of craftsmen in the various crafts. The Engineering Group, under the supervision of a Senior Engineer, who reports to the Supervising Engineer, is located at Maintenance Division Headquarters. This Group is administrative 1y independent from plant operations and station maintenance and is responsible for administrative support to the Maintenance Division. This consists of, but is not limited to, Maintenance Administrative Procedure and Standard Work Instruction development, review, and distribution. 17.2.1.2.6 Fossil / Hydro Generation Division The Fossil / Hydro Generation Division is under the direction of a Superintendent, who reports to the Manager - Fossil / Hydro Production. The Fossil-Hydro Generation Division is composed of Fossil-Hydro Generating Stations, Steam Heat, and Fossil Services. Fossil Services is under the direction of a Superintendent, who reports to the Superintendent of the Fossil-Hydro Generation Division, and is composed of four sectionst Performance, Training, Methods, and Fuels. The Performance and Fuels Sections are not involved with Quality Assurance activities at LGS. O Rev. 46, 03/86 17.2-16

LGS FSAR f.s 17.2.1.2.6.1 Training Section The Training Section, under the supervision of a Superintendent, who reports to the Superintendent, Fossil Services, is programs in fossil-hydro operations and supports the Nucle \\ responsible for preparing and conducting various training?ar Training Section, as required. In additi9n,0(thef rainin'g Section T administers the PECo qualifying examinationTprogramfor personnel of the Generation Divisions, as a "' fate Q b N ~ g. y ess 1:WM gk))k l 17.2.1.2.6.2 Methods Section E The Methods Section under the supervision of a Superintendent, who reports to the Superintendent, Fossil Services, is responsible for the promulgation of rules and procedures that implement the departmental principles that are necessary to provide adequate safety protection to personnel and equipment in Electric Production Department facilities. This responsibility does not include safety protection to personnel and equipment in the nuclear generating station from exposure to and the hazards r-of radioactivity. b] These rules and procedures are directed at the protection of personnel, in, on, or around machines or equipment during repair, maintenance, operation, and associated activities, from injury due to unexpected energization or start-up of the equipment or These rules are implemented by affixing appropriate process. lock-out/ tag-out devices to the machines or equipment energy isolating devices. The Methods Section is responsible for the preparation, control, and distribution of the book entitled, Rules for Permits and Blocking. The Methods Section is also responsible for the investigation of on-the-job accidents, as directed by the Superintendent, Fossil-Hydro Generation Division. 17.2.1.2.7 Plant Operation Review Committee (PORC) The organization and responsibility of the PORC are described in [ Section 13.4 and are defined by the Technical Specifications and implemented by Administrative procedures. 17.2-17 Rev. 46, ^1/86

LGS FSAR 17.2.1.2.8 Nuclear Review Board (NRB) The organization and responsibility of the NRB are described in Section 13.4 and are defined by the Technical Specifications. 17.2.1.3 Encineerino and Research Department The Engineering and Research Department (Figure 17.2-6) is responsible for plant design, procurement, construction, and quality assurance during the construction of Limerick Generating Station and for major modifications to Limerick during the operations phase. The Department employs nearly 1000 technical personnel to accomplish this task. In addition to this normal staff, the Department engages consultants or contractors to supplement and extend its capabilities in fields of specialized technology or expertise. 17.2.1.3.1 The Department is directed by the Vice President-Engineering and Research, assisted by the Manager. They have responsibility for the activities of the six divisions which comprise the Department: Mechanical Engineering, Electrical Engineering, System Planning, Construction, Engineering Design, Research and Testing Division, and Quality Assurance Section. The Engineering and Research Department interfaces with the Electric Production Department in that it furnishes engineering services to the Electric Production Department in the areas of vendor QA evaluation and surveillance, and major modification work as requested by the Electric Production Department.

Also, technical matters relating to station operation and station modifications can be referred to the Engineering and Research Department where they are analyzed by specialists in various disciplines.

The Engineering and Research Department may delegate work to consultants in a manner similar to that of the Design and Construction phases of the plant. The activities of the Engineering and Research Department are coordinated by the Mechanical Project Engineer and the Electrical Project Engineer. The Project Engineers are responsible for: l i Rev. 46, 03/86 17.2-18

l LGS FSAR (~'\\ U a. Assigning responsibilities related to modifications to the appropriate divisions, sections, branches, and groups. ) Acting as the primary interface betweeni ECo and maj'or b. contractors (such as the origina.JSSS 'and lA/E)' when ? such contractors are employ "-(3.X l g(. \\Ma c. Coordinating plans and schedu s. d. Certain administrative aspects such as document distribution and coordination, and maintenance of the project file. 17.2.1.3.2 Quality Assurance Section The Quality Assurance Section is under the supervision of the Engineer-In-Charge, Quality Assurance Section, who reports directly to the Vice President - Engineering and Research. p(-) Administrative support is provided by the Chief Mechanical Engineer. The Quality Assurance Section (Figure 17.2-7) has sufficient authority and organizational freedom to identify quality problems; to initiate, recommend, or provide solutions; and to verify implementation of solutions. This authority is sufficient to stop work or control further processing, delivery, use or installation. The Quality Assurance Section performs the following: a. Control and maintenance of the PECo E&R Department GA Plan for Limerick. b. Review and approval of E&R Department initiated procurement documents for inclusion of appropriate quality requirements. c. Establish and maintain the list of Evaluated Suppliers (ESL). d. Audits of vendors and E&R Department quality related activities to assure that the applicable OA program is i being implemented. PECO groups (outside the E&R d Department) which perform activities affecting the 17.2-19 Rev. 46, 03/86 l

LGS FSAR quality of Modifications for which the E&R Department is responsible shall also be subject to audit. The qualification requirements for Engineer-in-Charge, Quality Assurance Section include a broad background and working knowledge of plant engineering and construction. This position is considered by PECo to be a senior one which is subjected to an internal review reserved for management positions at this level. 17.2.1.3.3 Mechanical and Electrical Engineering Divisions The Mechanical Engineering Division (Figure 17.2-8), under the Chief Mechanical Engineer, has prime responsibility for the design and construction of company facilities, and accomplishes its purpose through project coordination and design review of mechanical plant equipment and components. Five sections (Nuclear and Environmental, Civil, Power Plant Design, Power Plant Services, and Industrial) comprise the Division. The Electrical Engineering Division, (Figure 17.2-9), under the Chief Electrical Engineer, has responsibility for electrical design of the company facilities and accomplishes its purpose through the design review of plant electrical equipment components. Five sections (Station Engineering, Field Engineering, Computer Engineering, Control Engineering, and Transmission and Distribution Engineering) comprise the Division. 17.2.1.3.3.1 Civil Section The Civil Section, under the direction of the Engineer-in-Charge who reports to the Chief Mechanical Engineer, is composed of two Branches: Structural Branch and Hydraulics Branch. Review of applicable plant design are made by the two branches. 17.2.1.3.3.2 Nuclear and Environmental Section The Nuclear and Environmental Section is under the supervision of the Engineer-in-Charge who reports to the Chief Mechanical Engineer. The Section is composed of two Branches: Nuclear Branch and the Environmental Branch, l Rev. 46, 03/86 17.2-20

LGS FSAR The Nuclear and Environmental Section is responsible for Interface between the Electric Production Department and a. the Engineering and Research Department for activities related to nuclear fuel and special nuclear material. b. Establishment and implementation of the PECo Nuclefeg Fuel Fabrication Quality Assurance Program includingt9 ns(M o go m Review and evaluation of thedfu$<lifabrl'cator's 1. nuclear material acco 46111tyfand10AE ~ ogram ~ against applicable NR 4 ion 2. Conduct of audits of the fuel fab or's QA and nuclear material accountability pfogram, including audits of fabrication, destyn control, and W' packaging activities. 3. Review of QA/QC documentation and records of O nonconforming materials related to fabrication of nuclear fuel for PECo. 4. Review of QA/pc documentation and data generated by the fabricator during fabrication of PECo fuel. 5. Special testing and inspection of fuel components as determined to be appropriate. 6. Recommending receipt inspection criteria to the station superintendent or designated representative: Determination of fuel cycle requirements including c. uranium ore, conversion, enrichment, fabrication, and spent fuel shipping and disposal. Evaluation of offers to supply fuel cycle services. d. Administration of fuel cycle service contracts. O Calculation of fuel cycle costs and burnup charges. e. 17.2-21 Rev. 46, 03/86 l

LGS FSAR O f. Nuclear material accountability prior to receipt of fuel assemblies by PECo. g. Reload licensing services. h. Establishing and maintaining a steady-state computer model of the reactor core. i. Coordination and review of licensing documents. 17.2.1.3.3.3 Power Plant Design Section The Power Plant Design Section is under the supervision of the Engineer-In-Charge, who reports to the Chief Mechanical Engineer. The Section is responsible for reviewing the design of major mechanical power. generation equipment and systems. 17.2.1.3.3.4 Power Plant Services Section O The Power Plant Services Section, under the direction of the Engineer-In-Charge who reports to the Chief Mechanical Engineer, is composed of two branches: Station Services Branch and Energy Services Branch. The Power Plant Services Section is responsible for reviewing the design of auxiliary mechanical equipment and systems. 17.2.1.3.3.5 Industrial Section The Industrial Section, under the direction of the Engineer-In-Charge who reports to the Chief Mechanical Engineer, is composed of two branches: Architectual Branch and Building Facilities Branch. The section is responsible for reviewing the design of ventilation, heating, air-conditioning, and fire protection systems. 17.2.1.3.3.6 Station Engineering Section The Station Engineering Section, under the direction of the Engineer-In-Charge who reports to the Chief Electrical Engineer, l Rev. 46, 03/86 17.2-22

LGS FSAR O is composed of four branches: Nuclear Generation Branch, Fossil-Hydro Generation Branch, Substation Branch, and Station Equipment Branch. 17.2.1.3.3.7 Field Engineering Section The Field Engineering Section, under the direction of the Engineer-In-Charge who reports to the Chief Electrical Engineer, is composed of three branches: Fossil-Hydro Branch, SubstatTon f@gg h - J Branch, and Nuclear Branch. fy,, k is t. S, rM The Field Engineering Section is res nefbblforl1thefollowing: p-g a. Reviewing the design docume or t ation and determining, for the Electrical Engin

Division, the testing to be performed by the Fi Engineering Section to demonstrate that the modification will perform adequately in service.

The Field Engineering Section may also determine electrical equipment testing to be performed by the Research and Testing Division. b. Providing i'nstructions/ procedures for the performance of testing by Field Engineers. c. Evaluating and accepting or rejecting test results unless another organization is specified. d. Maintaining a log of reports of nonconformances initiated by them. 17.2.1.3.3.8 Computer Engineering Section The Computer Engineering Section, under the direction of the Engineer-in-Charge, who reports to the Chief Electrical Engineer, is composed of two branches: Computer Applications Branch and Engineering Applications Branch. The branches are responsible for engineering review, design, and consulting functions as they apply to process computers. O 17.2-23 Rev. 46, 03/86

LGS FSAR 17.2.1.3.3.9 Control Engineering Section The Control Engineering Section, under the direction of the Engineer-in-Charge, who reports to the Chief Electrical Engineer, is composed of three branches: Nuclear Control Branch, Fossil-Hydro Control Branch, and Protective Relay Branch. The branches are responsible for engineering review, design and consulting functions as they apply to instrumentation and control equipment, and for engineering review, design, and consulting functions as they apply to protective relaying. 17.2.1.3.4 Construction Division The Construction Division (Figure 17.2-10) is under the supervision of the Office of the General Superintendent and consists of various Sections, Branches, and Groups which are responsible for the following activities associated with modifications for which the E&R Department is responsible: a. Planning, scheduling, and implementation of modification. O b. Receipt, receipt inspection, and storage of procured materials, parts, and components. c. Providing installation instructions. d. Preparing and implementing receipt and installation QC inspection requirements. 17.2.1.3.4.1 The Office of the General Superintendent, consisting of the General Superintendent and the Assistant General Superintendent, coordinates and supervises the work of the Electrical and Mechanical Sections and the Construction Division's QC Group. The Electrical Section Superintendent and the Mechanical Section Superintendent are responsible for the work of the individual Branches within their respective Sections. The Field Forces Branches, headed by the Supervisors-Field Construction, consist of Supervisors, foremen, subforeman, and skilled craftsmen of various trades who are responsible for the actual installation of modifications. l Rev. 46, 03/86 17.2-24

LGS FSAR ~ 17.2.1.3.4.2 The Construction Engineers Branches, headed by the Supervising Engineers, consist of group leaders, construction engineers, and field assistants who are responsible for planning'and scheduling modifications and for following work performed by the fjeld forces or the contractors. . c $ 17.2.1.3.4.3 1 The Construction Division Senior Engineer is responsible for establishing and implementing-the Construction Division QC inspection program. The Senior Engineer-QC has no responsibility for scheduling or cost. The qualification requirements for i Senior Engineer-QC include a background in construction practices and procedures and a working knowledge of applicable codes and specifications. The responsibilities of the Senior Engineer-QC 4 includes preparing, revising, and controlling distribution of . Construction Division Procedures, providing QC indoctrination and training for Construction Division personnel, overseeing the - activities of the Engineer-QC and Construction Division QC group, and providing a liaison between the Construction Division and the i Quality Assurance Section. The-Senior Engineer - QC effects implementation of.the QC program through the authority of the Office of the General Superintendent. The Engineer-QC is the site representative of the Senior i Engineer-QC. The Engineer-QC is responsible for directly overseeing the QC inspection activities of the Construction Division Site QC Group and assisting the Senior Engineer-QC with I job responsibilities. The Construction Division DC Group will be comprised of f appropriate disciplines,-such as mechanical, electrical, and structural. The QC Group is responsible for inspection of work l performed by the field forces, performing receipt inspections of l procured material, identifying and reporting nonconformances, and verifying corrective action in accordance with established 4 procedures. The QC Inspectors have the authority to stop unsatisfactory work and to control further processing or installation of nonconforming material. This stop-work authorization will be delineated in applicable procedures.- 3 - Personnel will be assigned to the QC Group on a continual basis l. and will be qualified in accordance with Regulatory Guide 1.58, as described in Appendix 17.2B.II. i 17.2.1.3.5 Research and Testing Division () i I 17.2-25 Rev. 46, 03/86 l -..w-. -.. ~.. ._---.---w,, ,+m ---.--..-ee-.- ,--..,_.---.-,.r..e, --=.-r-- ---,me.----w--- -mw,---e-..-,ef.---,,-,,.w-re-,-,.,,,,--m-w

LGS FSAR O The Research and Testing Division (Figure 17.2-11) is under the supervision of the Office of the Director, Research and Testing. The Division is involved in Limerick activities as follows: 17.2.1.3.5.1 The Metallurgical Group of the Energy Conversion Research Section is responsible for activities performed under the E&R QA Plan in the areas of metallurgy, nondestructive testing, and welding. 17.2.1.3.5.2 The responsibilities of the Research and Testing Division include: a. Planning, scheduling, and performf.ng installation and testing. b. Providing installation and testing instructions as h appropriate. c. Preparing and implementing installation and testing QC inspection requirements. d. Conducting tests of instrumentation and control equipment, protective relays and devices, transformers, switchgear, generators, voltage regulators, and computers. e. Calibrating measuring and test equipment. The Station Test Section is also responsible for the testing, calibration, and maintenance of instrumentation and control l equipment. These activities are originated through the LGS l operating staff and are performed under the 00A Program. 17.2.1.3.5.3 The Research and Testing Division OC Group is comprised of appropriate disciplines and has no responsibility for scheduling W and cost. This group is responsible for inspecting work Rev. 46, 03/86 17.2-26

LGS FSAR O performed by the field forces and for performing their I nonconformance reporting and corrective action responsibilities i in accordance with established procedures. The QC Inspectors have the authority to stop unsatisfactory work and to control further processing or installation of nonconforming mahecial'.\\ This stop-work authority will be delineated in appli' cable \\ procedures. Personnel will be assigned to therQCxgroup'on.a 9 continual basis and will be qualified in g('cordance with~ g ~ infl Regulatory Guide 1.58, as described Q .712B.tII. g y' 17.2.1.3.6 Engineering Design Divi ih\\ The Office of the Chief Design Engineer (Figure 17.2-12) reports to the Office of the Vice-President, Engineering and Research, and consists of the Chief Design Engineer and the Assistant Chief Design Engineer. The Engineering Design Division is responsible for the following work: a. Receiving, reviewing, processing, and responding to vendor drawings and document submittals required by procurement documents initiated within the Engineering and Research Department. b. Establishing'and maintaining a permanent drawing storage and retrieval system. c. Performing detailed design work based on criteria provided by the Mechanical and Electrical Engineering Divisions. d. Preparation and review of modification and as-built drawings. e. Initiating procurements and specifications as required by Electrical and Mechanical Engineering Divisions. 17.2.1.3.7 The responsibilities of the various EER Department groups are discussed more fully in the description of the OA program elements in Section 17.2B. O 17.2.1.3.8 17.2-27 Rev. 46, 03/86 l

LGS FSAR The PECo E&R Department Quality Assurance Plan for Limerick Generating Station and revisions thereto are approved by the Vice-President of the E&R Department and by the Director, E&R Quality Assurance Division with OA Plan Exhibits and Appendices and revisions thereto approved by the Director, E&R Ouality Assurance Division. 17.2.1.4 Purchasino and General Services Department Purchasing and General Services (Figure 17.2-13) is under the direction of the Vice President, Purchasing and General Services, who reports to the President and Chief Operating Officer of the Company. Purchasing and General Services is composed of five departments: Insurance, Fuel Procurement, Service Operations, Purchasing, and Real Estate. 17.2.1.4.1 Purchasing Department The Purchasing Department, under the supervision of a manager, is responsible for purchasing all equipment, ma'terial, spare parts, and services as requisitioned by the Stores Division or other requisitioning organizations. 17.2.1.4.2 Service Operations Department Under the supervision of Manager-Service Operations Department is the General Superintendent, Stores Division. The Stores Division is responsible to requisition, receive, document receipts, store, issue and inventory supplies, spare parts and other procured materials. Under the supervision of Manager - Service Operations Department is the General Superintendent, Office Systems and Communications Division. The Office Systems and Communications Division is responsible for the offsite storage of nuclear records from Peach Bottom, Limerick, and the main office. 17.2.1.5 Legal Department The Legal Department (Figure 17.2-14) is directed by the Vice President and General Counsel, with the aid of the Associate General Counsel. The Department has responsibility for the Rev. 46, 03/86 17.2-28

LGS FSAR k_s 1 activities of the two divisions that comprise the Departments l Legal Division and Claims-Security Division, a/ est p ;: 17.2.1.5.1 Claims-Security DivisibnN d s v y [tG.i, (. W 1 y u The Claims-Security Division is under the sup on of the Manager, Claims-Security Division who reports to the Associate General Counsel - Legal Department. The Director of Security, who reports to the Manager, Claims-Security Division, is responsible for the overall security on a company-wide basis. l 17.2.1.6 Personnel and Industrial Relations Department l i The Safety Division is under the direction of a Director who reportr, to the Manager, Personnel and Industrial Relations. The Safety Division Fire Protection Section is under the supervision of che Company Fire Marshal who reports to the Director of Safety. The Fire Protection Section, in conjunction with Electric Production site personnel, perform or arrange to perform r-certain fire equipment testing and inspections, both routine and (g) as required by Technical Specifications. In addition, the Safety Division Fire Protection Section is responsible for the procurement, testing, replacement, and record keeping of fire hoses, extinguishers, fire brigade self-contained breathing apparatus,.and other fire equipment, as required. The Company Fire Marshal is responsible for the review of fire protection system designs, as requested. The Safety Division is responsible for at least a once per year review of housekeeping practices that affect safety. The Safety Division assigns a Safety Representative to each nuclear power plant so as to provide a constant review of all industrial safety practices that affect personnel safety. 17.2.1.7 Finance and Accounting Department l The Nuclear Records Section, within the Finance and Accounting Department, is under the direction of a Supervisor who reports to the Manager, Systems Support Division. The Document Administration Center (DAC) in Philadelphia and at LGS are each under the direction of a Supervisor, who reports to the Supervisor / Project Leader, Nuclear Records Section. See Figure (~,s 17.2-16. ) 17.2-29 Rev. 46, 03/86

LGS FSAR O The Supervisor-DAC is responsible for task delegation to ensure creation, preservation, and protection of PECo's record copy of nuclear related quality assurance documents that have been submitted to the DAC. In addition, the Supervisor-DAC is responsible for assuring that the environmental conditions in the temporary records storage area are checked daily, for conducting the quarterly inspection of records stored temporarily in the records vault, and for arranging transfer to the permanent off-site records center. DAC personnel are responsible for: stamping sequence numbers on records; indexing records into the Nuclear Records Management System (NRMS) computerized data base; retrieving documents; microfilming records; verifying legibility of microfilm, and disposition of records. O O Rev. 46, 03/86 17.2-30

4 s) O p-a n -t ' A(\\ W g (1 3 , g h \\\\T(gh ' tV[si -,2> #' ,) gh,' O, W s. n b"] d _ c'J OFFICE OF THE CHIEF E ) A CHAIRMAN OF THE SOAR D CHIEF EXECUTIVE OFF - o PRE 90ENT ANO T O CwiE F OPER ATING OFriCE R y '.... r NUCLEAR COMWE RCIAL CORPORATE I'ICI"'O LEGAL NOIN,DU,STR AL POWE R OPERATONS COuwuP?tCATONS ngt y ogg PRODUCTON Vue Presase-t vce Pressdent Voce Presasent Vre Premdent Vue Premnant g, 5 I I O IC A O 0,mRCwyn FINANCE AND l E NGINE E RING CAS caugnat gc q yn, ,g p ACCOUNTING g AND RESEARCH OPE R ATIONS AND DISTRIBUTION ADMINISTRATON SE RVICES , O I, g v_ Pr -t v_ e-t ,e-t I O TREASURER SECRETARY DivlSON CONOwiNGO I MANAGER $ POWER COMPANY Dete=we testern y, % g

N Schwy a westeen REPORTING RESPONSI81LfTY-A Ch.ef E secutae Owicer O

Ch.' Ooorei-e Ome-LIMERICK GENER ATING STATION UNITS 1 AND 2 FINAL SAFETY ANALYSIS REPORT COMPANY ORGANIZATION CHART FIGURE 17.21 R EV. 46,03/86

2 I AD MINIST R ATIVE ASSISTANT I FOSSIL. HYDRO PRODUCTION Manager I 1 SYSTEM OPER ATION F OSSIL-HYD R O SE RVIC DIVISION GENERATION DIVISION DIVISid Superintendent Superintendent Superinten Asst Superintendent I I FOSSIL SERVICES SA STEAM HEATING ENV RONM NTAL AF F AIRS Supenntendent Supenntendent PERFORMANCE SECTION CHEMIS SECTli Engineer-in Charge Chief Ch St ation Superintendent Supn#$ndent n TRAINING CON 0WINGO SECTION COMPU APPLICA' = C BY Superintendent SECTli Engineer-in DELAWARE METHODS SECTION EDDYSTONE COST SECTit RICHMOND Superintendent SCHUYLKILL Engineer-in FUELS SOUTHWARK/ SECTION CHESTER Superintendent I i I

r \\ VICE PRESIDENT nCT e [s Y .Ic, ,. d *p .cs g U. SA iM Q M "' ) k B hTCLEAR 1 PRODUCTION Manager Asst To Mgr. 1 i ES M AINTEN ANCE NUCLEAR QUAlllY ASSURANCE N OlVISION GENERATION DIVISION DIVISION lent Superintendent Superintendent Superintendent / I I a $(p,E^N NUCL [ LIMERICK STATION PEACH BOTTOM F CE iER SECTION Manager Superintendent Manager Superintendent Supermtendent Supermtendent Superintendent Superintendent Operations Plant Services Operation: Plant Services TRY MECHANICAL NUCLEAR LICENSING )N SECTION SAFETY SECTION SECTION tmist Superintendent E ngmeer-in-Charge Engineer 4n Charge E ELECTRICAL 'l0NS SECTION NUCLEAR h H ADI Ail 0 N )N TR AININ G PROTECTION = SECTION SECTION Charge l Superintendent Superirnendent Director P APERTURE IN FUEL EMERGENCY CARD PREPARE 0 NESS MANAGEMENT Ch SECTION SECTION 1 Engineer in-Charge Director gg perture C-- STAFF ~ ENGINEER LIMERICK GENERATING STATION UNITS 1 AND 2 FINAL SAFE EY ANALYSIS REPORT ELECTRIC PRODUCTION DEPARTMENT FIGURE 17.2 2 R EV. 46,03/86 205626/68-CI

~ I t,y SUPERINTENDENT STATION ELECTRICAL MECHANICAL 2 \\ SECTION SECTION SECTlON 1 Superintendent Superintendent Superintendent,. y_ --, 3-PEACH BOTTOM ELECTRICAL MOBILE i C :S BRANCH STATION BRANCH GROUPS Supv. Engineer Senior Engineer Supv. Engineer Supv. Engineer ADMINISTRATIVE LIMERICK STATION TECHNICAL SERVICES STATION BRANCH SUPPORT Supervisor Senior Engineer Sr. Engineer Supv. Engineer (m 8 Supervisor Supervisor ENGINEERING GROUP OREGON SHOPS EDDYSTONE Sr.E W r STATION Supv. Engineer FIELD SERVICES Supervisor TRAINING & TESTING TECHNICAL SUPPORT Sr. Engineer l

INTERFACE LIMERICK GENERATING ST ATION UNITS 1 AND 2 FINAL SAFETY ANALYSIS REPORT C\\

( j MAINTENANCE DIVISION 'v ELECTRIC PRODUCTION DEPARTMENT FIGURE 17.24 R EV. 46, 03/86

,-~s (x STATION SECTION Superintendent I LIMERICK STATION LGS PLANT STAFF "~~~~ Supenising Engineer Maintenance Engr. Supervisor TECHNICAL SUPPORT (SITE) Engineer - Su6ervisory e'.,, dj,,s'[l.,,D Engineer l ig s 3 ELECTRICAL \\yUMN ICAL3 '. GROUP Oq$f Foreman F Asst. Foreman Asst. Foreman Subforeman Subforeman I l ~., l PlPING CONTRACTOR GROUP COORDINATION GROUP Foreman Foreman Asst. Foreman Asst. Foreman Subforeman Subforeman AUXILIARY GROUP Foreman Asst. Foreman Subforeman

OFFSITE INTERFACE LIMERICK GENERATING STATION UNITS 1 AND 2 FINAL SAFETY ANALYSIS REPORT l

l m LIMERICK MAINTENANCE GROUP ! [O i t MAINTENANCE DIVISION ELECTRIC PRODUCTION DEPARTMENT t FIGURE 17.2-5 R EV. 46,03/86

J -j-PU RCHASING INSURANCE SERVIC DEPARTMENT DEPARTMENT DEI Manager Manager Supervisor BUILDING MINORITY VENDOR MANAGEMENT ~ DEVELOPMENT DIVISION Director General Superintendent Superintendent COMMODITIES ~ SECTION Supervising Buyer STORES DIVISION SERVICES ~ SECTION General Superintendent Supervising Buyer Superintendent I SYSTEMS ~ SECTION Supervising Buyer ( I

\\ MICE PRESIDENT ADMINISTRATIVE ASST. E OPERATIONS FUELPROCUREMENT REAL ESTATE 'A'5TMENT DEPARTMENT DEPARTMENT e--s ' Manager Manager W." ~., Manager a p i 3 g t' Q' n,i., a \\.,. Manager a. :iyP t;u ". ~,I iA J1 h "sst, J e q b 3., Q Sj \\d 3 ('j CbVEYANCING F1 FOSSIL FUEL C IONS SECTION SECTION DIVISION General Superinterxlent Supervising Buyer Supervisor Superintendent NUCLEAR FUEL PROPERTY SECTION MANAGEMENT SECTION Supervising Buyer Supervisor TRANSPORTATION DIVISION PROPERTY ACQUISITION General Superintendent SECTION Supervisor Supt. Operations N Supt. Maintance g SURVEY ~ ggD SECTION Supervisor Also Availalde @ Aperture Ca"i LIMERICK GENER ATING STATION UNITS 1 AND 2 FINAL SAFETY ANALYSIS REPORT PURCHASING AND GENERAL SERVICES DEPARTMENT FIGURE 17.213 REV. 46,03/06 %oSolo/M-OZ

~. '%Y n P' ' \\ 'l 's .~~c' 3 hbh Nh ' w OFFICE OF THE VICE PRESIDENT AND GENERAL COUNSEL Vice President and General Counsel Associate General Counsel CLAIMS SECURITY LEGAL DIVISION Assistant General y, Coumel i; Assistant Counsel ADMINISTRATIVE ASSISTANT CLAIMS S[CURITY Director Director Asst. to Director Asst. Director Supervisor Senior Agent LIMERICK GENERATING STATION UNITS 1 AND 2 FINAL SAFETY ANALYSIS REPORT LEGAL DEPARTMENT FIGURE 17.214 REV 46,03/86

1 / I! Ci e gc (n. I E LECTRIC PRODUCTION DEPARTMENT VICE PRESIDENT g I I 1 + F OSSIL-H Y DRO NUC LE AR PRODUCTION PRODUCTION MANAGER [ MANAGER k I I I MAINTENANCE NUCLE AR GENER ATION QUALITY ASSURA5 DIVISION DIVISION ' DIVISION ~ SUPERINTENDENT A SUPERINTENDENT g SUPERINTENDEN' I I MECHANIC A L SECTION (gg MANAGER SUPERINTENDENT g, SENIOR ENGR SUPERINTENDENT ^ OPE R ATIONS /4 AUDIT SECTION ' ENGINEERING SECTION GENER AL SUPVR. - OA

ENGINEER - QA l

INSERVICE OPE R A TION S l 'NSPECTION GROUP E NGINE E R ENGR - SUPERVISORY l

ENGINE ERING l

STAFF'/ HIFh ECH ICI // A ,g/ / ADVISOR' /,//,/ Q* 2. MM0M / "I

f'/P8 APS' StkE N

'N/NCORP.N2A NL'G's SIT'ENM j%A SUPERVISOR,; 'tA SUPE RVISOf}; ' OA SUPERVISOR [ yAbDjTO' S MEdD)b'R'S h UDi[($fiS [ [. .] INDICATES ORC ANi2ATIONS PERFORMING VERIFICATION ' OF OUALIT Y-RE L ATED ACTIVITIES APPRCxlM AT E ST A F FING LEVE L SE E FIGURC 17 2 i FOR ADDITIONAL DET AIL h SEE FIGURE 17 2 -2 FOR ADDITIONAL DETAIL h SE E FIGURE 17 2 3 FOR ADDITION AL DET AIL h SEE FIGURE 13.1 2 FOR ADDITIONAL DE Tall h SE E F IGURE 17 2 6 F OR ADDITION AL DETAll h SEE fl6URE 112 7 FOR ADDITION AL DE T AIL h SEE FIGURE 17 2 to FOR ADDITIONAL DETAIL h SEE FIGURE 11 ~i 11 F OR ADDITION AL DE T All SEE FIGURE 17 2 4 FOR ADDITION AL DET All g NOT RESPONSIBLE FOR SIGN OF F FUNCTION J {

IAIRMAN OF THE BOARD HIEF EXECUTIVE OFFICER PRESIDENT & h IEF OPERATING OFFICER 9 ENGINEERING & - < < gg,M RESE ARCH DEPARTMENT E,.. OFFICE OF THE, < N ' "! ks (il7 l ' VICE PRESIDENTV ' t OO * ,;9i $ h th I bE TESTING & CONSTRUCTION e ABORATORIES DIVISION s ogy:StoN GENERAL GENERAL SUPE RINT EN DE NT SUPERINTENDENT A DIVISION OUALITY CONTROL. QUALITY CONTROL N ECTI N GENER A L' SbPVR.- OC ~^ ' DIR ECTOR ',') g SR. EN GIN E E R - OC LEAD QUALITY ENGR. l 1 J ~ l l l l ~ , - PB APS $1TE. . ) LGS SITE.

OC SUPERVISOR

OC SUPE RVISOR ENGl E - OC ENGl E R - OC INSPECTORS

~ ~ ~ ~ ~ ~ ~ ~~~~~~~~

ENGIN EERS '

ENGINEERS -INSPECTORS INSPECTORS ..%w-INSPECTORS -lNSPECTORS T1 EMM ' FIELD SECTION OFFICE SECTION CARD Also Available On Apertente VA LIMERICK GENERATING STATION UNITS 1 AND 2 FINAL SAFETY ANALYSIS HEPORT FUNCTIONAL QA / QC DIAGRAM FIGURE 17.215 R EV. 46. 03/86 8405020/62- 03 I

~3 FINANCE AND ACCOUNTING DEPARTMENT Vice President S 4.b fy7 1 \\ n,%e R&}. INFORMATION SYSTEMS 7 j f 3sM o-sgn SYSTEMS SUPPORT DIVISION Manager Assistant Manager NUCLEAR RECORDS PROG MMING SECTION SECTION Supervisor Supervisor Project Leader USER SUPPORT SECTION DOCUMENT ADMINISTRATION CENTERS Supervisor Supervisors Philadelphia TECHNICAL Limerick SUPPORT Peach Bottom SECTION Supervisor LIMERICK GENERATING STATION UNITS 1 AND 2 FINAL SAFETY ANALYSIS REPORT ( SYSTEMS SUPPORT DIVISION g FINANCE AND ACCOUNTING L DEPARTMENT FIGURE 17.216 R EV. 46,03/86

LGS FSAR' l ,1 17.2A ELECTRIC PRODUCTION DEPARTMENT OUALITY ASSURANCE ~, DURING THE OPERATIONS PHASE This section describes the Quality Assurance Program which will be applied by the Philadelphia Electric Company Electric Production Department to activities affecting the quality of safety-related structures, systems, and components of the Limerick Generating Station during the Operations Phase. ] Appropriate portions of the Program will also be applied to = packaging of radioactive material consistent with the activity and proposed use of the package, i j This Program meets the requirements of 10CFR50, Appendix B and is based on compliance with NRC Regulatory Guides and Industry Standards as addressed in Appendix 17.2A-II. Sectionr13.5describestheadministrativeandimplementingt"O procedures which meet the requirements of the ElectriWProduction Quality Assurance Program and which will be l'emented ib'y}thed g' G 3 ( LGS plant staff. 17.2A.1 ORGANIZATION ( ~ l See Section 17.2.1. [ 17.2A.2 QUALITY ASSURANCE PROGRAM The operating philosophy of the Electric Production Department places emphasis and primary concern on the safety of its-employees and the public. Other considerations such as continuity of servic6 equipment protection, economic operation, and environmental effects are recognized as important but are secondary to human safety. The Department's many years of eugeriaa A operating generating c stations has evolved a wide spectrum of management measures directed toward efficient and safe operations. The Operational Quality Assurance (OOA) Program for the operation O-of LGS recognizes quality assurance as an interdisciplinary function involving many organiz.stional components (i.e. 17.2A-1 Rev. 46, 03/86

LGS FSAR O departments, divisions, sections, groups and individuals) and is ) l not regarded as the sole domain of the EP Quality Assurance (QA) l Division. Quality Assurance encompasses many functions and activities and extends to various levels in all participating j organizations. First line supervision is responsible for the i quality of the work performed under their supervision. Second line supervision may perform inspections or examinations of work functions associated with normal operation of the plant, routine maintenance, and certain technical services routinely assigned to the onsite operating organization where necessary to ensure quality. Independent inspections of non-routine maintenance and plant modifications shall be performed, as required, by qualified individuals who are organizationally independent of the individual or group performing the work. The Station Manager has overall responsibility for the execution of the administrative controls at the plant and implementation of responsibilities ' assigned to plant personnel by the EP OOA Plan. An overview of the Program is provided by personnel from the EP QA Division who are organizationally independent of Nuclear Generation and Maintenance Divisions. The EP QA Division shall ensure, through the Auditing and Quality Control Programs, that activities affecting quality are accomplished in accordance with the requirements of the OQA Program. 17.2A.2.1 With regard to the operation of the Limerick Generating Station, management recognizes the need to maintain a competent staff and to provide this staff with the support nec'essary to maintain operational safety. To meet this goal, certain activities conducted in the plant have been recognized as important to operational safety and specific management control measures have been set up to assure quality in these activities. Personnel shall be trained and indoctrinated in these activities which are pertinent to their job description and responsibilities, with due regard to the effective implementation j of the EP OOA Program. Management requires that operations be conducted in accordance with approved procedures and has established review and reporting mechanisms which provide prompt and effective. action when exceptions occur. The staffing of the station is such that certain disciplines (e.g., Chemistry, Testing, Stores and Purchasing, Maintenance) share high level supervision and management with other plants and facilities of the Philadelphia Electric Company. In such cases, the supervision and management reside at company headquarters, or other central facilities, and, by frequent communication and Rev. 46, 03/86 17.2A-2

LGS FSAR V plant visits, monitor the activities of their groups at LGS. This is an important aspect of the staffing which provides a great wealth of experience and knowledge in assuring proper operation of the plant. The station technical group i; composed primarily of graduate engineers who assist plant supervision in areas of operational surveillance, maintenance, plant monitoring, and testing. Additionally, Philadelphia Electric Company's own highly qualified Engineering and Research Department, which is responsible for the design and construction of the plant, is readily available for engineering consultation during operation. First and second line supervisory positions are norma)1yvf411ed by promotion of qualified personnel. This procedure assures knowledgeable and experienced checking and,,inspe'cti'on Cof t JSA progress work activities and is consi.deryd(ainoteworthySaspect of F(;y g, t.ygG1 operational safety. g Shift operation at a power plant i a most :kpoet'an activity that impacts greatly on safety. This activi%p46" concerned with the proper performance of the plant processes both during the /'~S shutdown and power phase. It involves surveillance of plant ) variables and manipulation of controls to maintain these variables at desired levels. Prompt and effective action during '~' plant upsets and equipment malfunctions is required. Management has taken measures in the area of training and staffing which enhances safety of operation and, in addition, requires mechanisms to be established which provide objective evidence that important operations are being performed in accordance with established procedures. Appropriate objective evidence, in the form of check-off lists, log records, and data sheets, is reviewed by appropriate supervision as specified in Administrative Procedures. Another important aspect of shift operations is communications. Communications between shift personnel and plant supervision, 'between one shift and succeeding shifts, and between staff group leaders and shift supervisors must be effective to assure safe operation. Viable mechanisms are established, where appropriate, to enhance inter-plant group communications to assure timely and effective communications. 17.2A.2.2 [ ] Training and qualification of plant operators is an on-going activity required to ensure safety ir operation. Training and \\/ retraining efforts are formalized and objective evidence is 17.2A-3 Rev. 46, 03/86

LGS FSAR O available for auditing purposes. On-the-job " hands on" type experience is designed into the program to a maximum practical degree. Records of each licensed operator's more important operations are maintained; e.g. reactor start-up and shutdown. Qualified instructors and training material are utilized. Evaluations of students' training progression and requalification status are maintained. The training program assures competent material selection and instruction. The requalification program is designed to maintain current operator competence and uses current NRC requirements. Training aids and individual study periods shall be utilized, as appropriate. Formal classroom instruction shall be scheduled. Evaluation of trainee's progress shall be documented. The training program also includes provisions for non-licensed personnel and general employee indoctrination. As appropriate to the duties and responsibilities of an individual, general employee training includes: general description of plant and facilities, job-related procedures, radiological health, emergency plan and procedures, industrial safety, fire protection program, quality assurance program, and security plan and procedures. Personnel performing quality-related activities shall be trained and qualified in the principles and techniques of the activities being performed. These areas include technical training, on-shift training, qualification or certification requirements, and qualifying tests, as appropriate for the job position. Administrative procedures shall delineate the scope, objectives and methods associated with the training program along with requirements for retraining and documentation of the training accomplished. The qualification requirements for plant personnel are described in Section 13.1.3. The Electric Production Department has taken predetermined and systematic action to ensure that LGS operations are conducted in a safe efficient manner. High employee loyalty evidenced by many years of continuous service and low employee turnover combined with specialized training programs and other employee benefits are recognized as significant contributors to quality in the operational phase. 17.2A.2.3 Surveillance testing of safety systems and instruments as required by the Technical Specifications is an activity which is an important contribution to the operational safety of LGS. W l Administrative Procedures require that these tests be conducted Rev. 46, 03/86 17.2A-4

LGS FSAR O in a high-quality manner by knowledgeable personnel familiar with the test procedure. System procedures are reviewed by PORC and approved by the Station Superintendent. System tests associated with process operation are conducted by the shift operations group with review by shift supervisioi.. Approved procedures and documented reports are utilized to ensure high quality in this activity. 17.2A.2.4 Work associated with radiation protection and chemistry is conducted under supervision of the Senior Health Physicist and Senior Chemist, respectively. The activities are divided into two types: first, those of a routine and non-complicated nature and second, those of a non-routine or complex nature. Activities of the first type are generally performed by members of the shift operations group. In this way, this group maintains competence in the area of radiation control and chemistry and provides the capability for 24-hour-per-day radiation and chemistry ror monitoring. The more complex studies and tests _areeperforme by members assigned to the technical group.,,o,The?importanc& o* j^ radiation control (ALARA), and che ' t(y. nJn'uclear:plaqb 4 g) operation warrants every effort to htablish!hightqdality in this s. activity. Mechanisms such as shif 4s1:1kwrittedreports, riath supervision plots, and log books will be review y app 1 as specified in Administrative Procedures. 'ey'piQhsand reviews will also be conducted by senior pla ervision as defined in Administrative Procedures. 17.2A.2.5 Mechanical and electrical maintenance at LGS will be performed by the Maintenance Division of the Electric Production Department as a service to the operating organization. The Maintenance Division is organizationally independent of the plant operating staff and reports through its Superintendent to departmental management. The Quality Assurance Division shall assign personnel to the station to provide quality control checking and inspection. The Maintenance Engineer who is part of the plant staff coordinates and serves as the operating staff - Maintenance Division interfacing agent. Instrument maintenance at LGS may be performed by the Testing and Laboratories Division of the Engineering and Research Department / as a service to the operating organization. The Testing and ( )) Laboratories Division is organizationally independent of the plant operating staff and reports through its General 17.2A-5 Rev. 46, 03/86

LGS FSAR O Superintendent to E&R Department Management. The Instrument and Control Engineer who is part of the plant staff coordinates and serves as the operating staff - Testing and Laboratories Division interfacing agent. Only qualified craftsmen are utilized to perform maintenance work. First and second level supervision have had specific quality training and are recognized as informal but a most important means of controlling quality. Installation of new components or the physical change in systems of a major nature is considered a modification activity which will normally be implemented by the Engineering and Research Department. Quality assurance measures and organization for modifications shall be implemented in a fashion similar to that used during plant design and construction with the additional assurance of review and approval by the Plant Operations Review Committee and, as appropriate, the Nuclear Review Board. 17.2A.2.6 The procurement of spare parts, materials, and services for LGS is initiated by cognizant personnel in accordance with approved policies and procedures. The Stores Division is an independent organization functioning as a service group to the Electric Production Department. The ordering, receipt, storage, and issuance of materials and services are accomplished in accordance with Stores Division, Corporate, OA Division, and plant procedures which incorporate suitable measures to ensure quality. Requisitions for materials or services are transmitted from the Stores Division or other authorized PECo entities to the Purchasing Department where buyers execute the orders in accordance with Company purchasing procedures and policies. Spare parts, materials, and services may also be obtained via Bechtel Power Corporation, the A/E for the plant. In this case, procurements are made in accordance with the same or equivalent procedures as used for plant construction, and appropriate certification will be provided to the plant staff upon delivery. l 17.2A.2.7 The Electric Production Department 00A Program for Limerick will be defined in the Limerick EP 00A Plan (Volume III, Operations Phase). The EP OOA Plan implements the policies and objectives of the Electric Production Department by addressing the managerial and administrative controls in various operational Rev. 46, 03/86 17.2A-6

LGS FSAR O activities such as: Startup, Training, Health Physics and Chemistry, Fuel /Invessel Material, Shift Operations, Surveillance Testing, Maintenance of Instruments, Maintenance-Electrical and Mechanical, In-Service Inspection, Stores and Purchasing, Modifications, Radioactive Waste / Material, and Plans. For each of these activities, the EP 00A Plan shall address the l 18 criteria of 10CFR50, Appendix B and describe how each activity is in compliance with the applicable criteria in Appendix B. In addition, the radioactive waste / material activity shall also address the requirements of 10CFR71, Subpart H, Packaging and Transportation of Radioactive Material,-Quality Assurance. Procedures are written to implement all aspects of the EP OOA Plan. A matrix of these procedures or documents is presented in Appendix 17.2A.I to demonstrate that 10CFR50, Appendix B criteria are fully implemented by documented procedures. view:ofiAdmi'nis & M% tfatAve The Superintendent - OA Division, in the Procedures, shall ensure that regul ,_y ide'commitmentg agbf included in the appropriate procedu \\{;ig s O All quality assurance program activities perf i pin Philadelphia Electric Company are subject to f " periodic audits by EP QA Division. These audits verify that organizations performing these activities are complying with and properly implementing their procedures. i Administrative procedures for the preparation of documents, such as drawings, specifications, and procedures ensure that the use l of appropriate equipment, suitable environmental conditions, and compliance with necessary prerequisites are considered, as necessary, to perform activities affecting quality under controlled conditions. The development, control, and use of computer code programs,. commensurate with its importance, shall be conducted in accordance with the appropriate provisions of this 00A program. Software, commensurate with its importance, used in the operational phase of Limerick Generating Station shall be subject to verification by Philadelphia Electric Company or other qualified personnel. Measures shall be established to ensure that computer codes are appropriate for their specific applications. The EP OOA Program shall be reviewed periodically by the Superintendent - OA Division to determine status and adequacy. 17.2A-7 Rev. 46, 03/86 L

r LGS FSAR Electric Production Department Management is informed on a continuing basis of the status and effectiveness of the quality assurance program through reports at Vice-Presidential Staff Meetings. 17.2A.2.8 The EP 00A Plan applies to activities affecting the quality of systems, components, and structures installed to prevent or mitigate the consequences of an accident which could be harmful to the public. These structures, systems and components are identified through the LGS Project 0-List and the Quality Assurance Diagrams. Although the measures discussed apply primarily to 0-listed equipment, they may also be applied in l varying degrees to non-0 listed equipment (e.g., Seismic IIA). The application of these quality assurance measures to non-O listed systems will additionally enhance operational safety. The LGS EP OOA Plan, including revisions thereto, shall be approved by the Superintendent - OA Division; Manager - Nuclear Production; and the Vice President - Electric Production Department prior to issue. Revisions to the EP OOA Plan may be made by the recommendations of Philadelphia Electric Company personnel. 17.2A.2.9 The EP Ouality Assurance Division is staffed with trained and qualified personnel, both on and off site, who are organizationally independent of other Electric Production Department Divisions and other PECo Departments. The EP OA Division has the primary responsibility to verify through the review of objective evidence and the performance of observations that the quality assurance program is being accomplished in accordance with the LGS EP 00A Plan. This verification is accomplished by means of Quality Control monitoring, inspections, and reviews and QA audits and surveillances. The Superintendent - OA Division, is responsible for developing and maintaining a quality assurance indoctrination and training program for Division personnel to establish proficiency in quality assurance / quality control and to qualify personnel in accordance with Division requirements and procedures. Rev. 46, 03/86 17.2A-8

LGS FSAR The EP OA Division may involve itself in the planning of quality-related activities as they deem necessary to ensure that quality assurance requirements are provided consistent with the importance of such activities. Resolutions of differences of opinion between audited and auditing personnel, regarding deficiencies or noncompliances identified by the EP OA Division shall be made by Department Management. EP OA Division personnel are authorized to stop work when such work is considered to be a serious quality degradation. .nrV

O

\\ u, 17.2A.2.10 Y q i i! d !u&,g j g.) UU ,3 nr The quality assurance program for LGS is docum dt written policies, procedures, and instructions and shal ga tied out throughout the life of the plant. O) The Superintendent - OA Division, shall review and approve al.1 D Administrative Procedures that implement the EP 00A Plan. l The administrative and implementing procedures and instructions pertaining to quality-related activities are written to accomplish those activities with appropriate equipment under suitable environmental conditions. 17.2A.2.11 Information concerning plant conditions and status will be made available to EP OA Division personnel to enable responsible OA supervision to determine when audits, surveillances, monitoring, or inspections should be performed. This information may be in the form of communications with plant management or staff personnel through daily or periodic meetings. In addition, during the daily inspection, EP OA Division personnel shall periodically review operating logs, maintenance work schedules, fuel hand.11ng operations schedule, in-service inspection program, and modif4-ation proposals, to ensure that EP OA Division personnel "re involved in day-to-day activities that are important to the safe operation of LGS. O 17.2A-9 Rev. 46, 03/86

LGS FSAR 17.2A.3 DESIGN CONTROL 17.2A.3.1 Measures shall be established and documented to ensure that the applicable specified design requirements, such as design bases, regulatory requirements, codes, and standards are correctly translated into specifications, drawings, procedures, or instructions. These measures shall include provisions to ensure that appropriate quality standards are specified and included in design documents. Changes or deviations from specified design requirements or quality standards shall be identified, documented, and controlled. Records of implementation of these design control measures, as defined in the design control procedures, shall be available for review. Design control measures shall be applied as necessary to identify and control design interfaces and for coordination among participating desian organizations. These measures shall include the establishment of procedures among participating design organizations for the review, approval, release, distribution, and revision of documents involving design interfaces. Design control measures are applied to items such as the following: reactor physics, stress, thermal, hydraulic, and accident analyses; compatibility of materials; accessibility for in-service inspection, maintenance, and repair; and include a delineation of acceptance criteria for inspections and tests and other design work on 0-listed items or systems. 17.2A.3.2 Plant modifications shall be controlled and administered by Administrative Procedures and shall be categorized as major or minor. Design and design control measures for minor modifications shall be established in Administrative Procedures for plant modifications. Major modifications shall be defined by LGS Administrative Procedures. The implementation of the Quality Assurance Program for major modifications is the responsibility of the Engineering and Research Department and shall be accomplished in accordance with Section 17.2B. Rev. 46, 03/86 17.2A-10

, ~- -= t j i LGS FSAR !O The initial determination of whether a particular proposed modification is to be considered major or minor shall be the responsibility of th9 station superintendent with the concurrence of PORC prior to the implementation of the modification. Administrative Procedures will be written which require that major and minor modifications be reviewed after completion of the i work to determine if the as-built installation differs from the original design, and that drawings and documents are revised, if required, to reflect the actual installation. i 17.2A.3.3 . q gm ~3 yr',c,;'A i g$ %.. ii ' ;' .J l Design control measures shall be app nyerify,orceb'eckthe 2 i adequacy of design, such as by the 6e')fedesign reviews, L$p"gethods,or f by the use of alternate or simplified calculat gg i by the performance of a suitable testing proge l Design adequacy of minor modifications shall be determined by an i independent design review in accordance with LGS Administrative Procedures. These reviews shall be performed by vendors, cognizant engineers on the plant staff, in the appropriate Division of the E&R Department, or in some cases by the i Maintenance Division or Services Division of the Electric Production Department. The reviews shall consist of reviewing the design, spot checking the calculations or analysis, and assessing the results against the original design basis and functional requirements. 17.2A.3.4 j k j Instructions for the design of minor modifications shall be written to require compliance to regulatory requirements as r defined in 10 CFR, Part 50.59, and as defined in the license application in accordance with the design basis of the l structures, systems, or components. l Minor modifications are normally of a scale which do not require j design interfaces and coordination among different design j organizations. Approval of minor modifications shall be delineated in LGS Administrative Procedures pertaining to Plant Modifications. ,!O i 17.2A-11 Rev. 46, 03/86 I l

LGS FSAR Design documents for minor modifications such as proposals, records, procedures and approvals shall be administered, maintained, and controlled in accordance with Administrative Procedures. 17.2A.3.5 Measures shall be established to assure that the modifications meet design, installation, inspection, testing and quality assurance standards. Testing of modifications assures system integrity and provides for evaluation of performance prior to operation. 17.2A.4 PROCUREMENT DOCUMENT CONTROL 17.2A.4.1 Heasures shall be established and documented to assure that applicable regulatory requirements, design bases, and other requirements which are necessary to assure adequate quality are included or referenced in the documents for procurement of items and services. Changes in procurement documents shall be subject to the same degree of control as was utilized in the preparation of the original document. To the extent necessary, procurement documents shall require vendors to provide a quality assurance program consistent with the pertinent requirements of 10CFR50 Appendix B or other appropriate measures shall be specified. Administrative Procedures for procurement shall establish provisions to ensure that the supplier furnishes the following records to PECo a. Documentation identifying the purchased items and the specific procurement requirements (e.g.,

codes, standards, specifications) met by the items.

b Documentation identifying any procurement requirements that have not been met. c. A description of those nonconformances from the l procurement documents that are proposed for disposition as accept-as-is or repair. l Rev. 46, 03/86 17.2A-12 i l

LGS FSAR The review and acceptance of these documents shall be described in the Limerick EP OOA Plan. Procurement documents shall include provisions for the following, as applicable. a. Supplier Quality Assurance Program b. Basic Technical Requirements Source Inspection and Aydit'; )1, [,4 7rW) c. \\W .x d. Documentation Requiremen e. Lower Tier Procuremente 17.2A.4.2 O v Measures shall be established in accordance with Administrative Procedures to control the preparation, review, approval, and issuance of procurement documents. Administrative Procedures shall require that a cognizant member of the requisitioning organization determine the technical and quality assurance requirements for a Nuclear Safety-related item or service. He shall determine the applicable specifications, drawings, details, and code requirements to be applied to the procurement document. He shall also determine any special controls to be applied such as vendor controls, hold points, tests to be performed, along with acceptance or rejection criteria, sub-vendor controls, vendor check points, test data, test results, special labeling, storage instructions, requirements for reporting nonconformances, shipping instructions, and documentation requirements. Personnel knowledgeable in QA practices shall review all " Nuclear Safety Related" requisitions for adequacy of quality requirements. O 17.2A-13 Rev. 46, 03/86

LGS FSAR 17.2A.4.3 Purchase orders shall be issued to cuppliers whose quality assurance programs have been evaluated for adequacy or other appropriate measures shall be defined to assure quality. 17.2A.4.4 The Stores Division, other authorized PECo entities, and Purchasing Department shall process only approved requisitions in accordance with PECO Procurement procedures and policies. The Purchasing Department shall not alter the requisition of any Nuclear Safety-Related item or service without prior approval of the requisitioning source, except for commercial items such as price, quantities, schedule, F.O.B. terms, etc. Prior approval is required from the responsible organization for cases where the requisitioning source is not the PECo organization responsible for the technical and quality aspects of the item or service. 17.2A.4.5 Requisitions for Nuclear Safety-Related items shall clearly indicate that the request is for " Nuclear Safety-Related" items. 17.2A.4.6 Procurement Documents shall be maintained in accordance with Section 17.2A.17. 17.2A.5 INSTRUCTIONS, PROCEDURES, AND DRAWINGS 17.2A.5.1 Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Instructions, procedures, or drawings shall include appropriate quantitative or qualitative criteria for determining that important activities have been satisfactorily accomplished. Rev. 46, 03/86 17.2A-14

LGS FSAR The activity may be prescribed in job specifications, work instructions, shop drawings, job tickets, planning sheets, operating or procedure manuals, test procedures, or any other type of written form, provided that the activity is adequately described. Quantitative criteria, such as dimensions, tolerances, and operating limits, and qualitative criteria, such as comparative workmanship samples, shall be specified, as appropriate, for determining satisfactory work performance and quality compliance. The review and approval of station procedures is described in Section 13.5. In addition, the POR Committee, whose members are knowledgeable in quality requirements and administrative n 75 7 controls, reviews the test and maintenance procedures thatiare'\\' WM @a ;n \\ (R developed in the modification process. i N 17.2A.S.2 Station Administrative Procedures shall be revie d by the POR Committee or by a subcommittee appointed by PORC and approved by the Station Manager or his designated alternates and the n Superintendent - OA Division, and shall be distributed to predetermined personnel. These administrative procedures shall v contain provisions which clearly delineate the sequence of actions for the preparation, review, approval, and control of activity implementing procedures, instructions and drawings. 17.2A.S.3 Implementing procedures, instructions, and drawings shall include, as appropriate, quantitative and qualitative acceptance criteria, signoffs, and inspection points to ensure that important activities are satisfactorily accomplished. Appropriate recording documents such as log books, work request forms, check-off lists, or data sheets, shall be used, when appropriate, to ensure compliance with the instructions, procedures, and drawings. Procedures may also include applicable reference to vendor equipment manuals, design drawings and specifications, prerequisites, special precautions, and the delineation of the work to be accomplished. O 17.2A-15 Rev. 46, 03/86

r LGS FSAR Equipment manuals and manufacturers' instructions shall be readily available for use. 17.2A.5.4 EP Ouality Assurance Division personnel shall, in the course of the Auditing or Quality control Programs, selectively review the adequacy, completeness, and effectiveness of implementing procedures, instructions, and drawings associated with activities performed under the EP 00A Plan. Administrative type procedures shall be written by other organizations participating in quality related activities supporting operation of LGS under the 00A Program. These procedures shall contain provisions which clearly delineate the sequence of actions for the conduct of safety-related activities. The Superintendent - OA Division shall review and approve these administrative procedures to ensure compliance with the LGS EP 00A Plan. 17.2A.6 DOCUMENT CONTROL 17.2A.6.1 Measures shall be established and documented to control the issuance of documents, such as instructions, procedures, and drawings, including changes thereto, which prescribe activities affecting quality. These measures shall ensure that documents, including changes, are reviewed for adequacy and approved for release by authorized personnel and are distributed to and used at the location where the prescribed activity is performed. Changes to documents shall be reviewed and approved by the same organizations that performed the original review and approval unless other organizations are specifically designated. The reviewing organizations shall have access to pertinent background information upon which to base its approval and shall have adequate understanding of the requirements and intent of the original document. 17.2A.6.2 Those participating in an activity shall be made aware of and l shall use proper and current instructions, procedures, and drawings, for performing the activity. Participating I Rev. 46, 03/86 17.2A-16

LGS FSAR O organizations shall have procedures for control of the documents and changes thereto to avoid the misuse of outdate'd ~ ori inappropriate documents. .,... c - J Qy \\ p) W vin Document control measures sh g v ', f 1 a. Identification of individuals gandrations responsible for preparing, rev ing, approving, and issuing documents and revisions thereto. b. Identifying the proper documents to be used in performing the activity, c. Coordination and control of interface documents. d. Ascertaining that proper documents are being used. e. Establishing current and updated distribution lists. f. A mechanism for temporary and emergency procedural changes. g. Submittal of approved, issued, controlled document to the Nuclear Records Management System for indexing and retention. Procedures will also prescribe the methods (such as training / reading lists) by which those personnel participating in an activity are made aware of modifications and document changes. 17.2A.6.3 Procedures shall be established for the preparation of documents (such as drawings, specifications, procurement documents, installation, and testing procedures) which prescribe activities affecting quality. The procedures shall provide sufficient controls to ensure that these type of documents are: O 17.2A-17 Rev. 46, 03/86

LGS FSAR a. Reviewed and approved by qualified personnel to ensure that they are technically adequate and that the applicable quality requirements are stated b. Issued in a controlled manner c. Changed, reviewed, and approved in the same manner as the original or as specified in the procedure d. Available at the location where the activity will be performed prior to commencing the work e. Controlled to prevent the inadvertent use of obsolete or superseded documents. f. Suomitted when completed to the LGS Document Administration Center for inclusion in the Nuclear Records Management System. 17.2A.6.4 LGS EP OOA Plan and EP Quality Assurance Division procedures and revisions thereto shall be controlled as per EP OA Division Procedures and Instructions Manual under the authority of the Superintendent, OA Division. 17.2A.6.5 LGS activity instructions, procedures, and drawings, delineated in the document control requirements of the EP OOA Plan, shall be procedurally controlled and approved in accordance with the Administrative Procedures under the authority of designated, responsible management. These controls establish individual responsibilities for the preparation, review, approval, and distribution that apply to the various quality related activities. O Rev. 46, 03/86 17.2A-18

LGS FSAR O 17.2A.6.6 Temporary and emergency procedure change mechanisms shall be provided in the Administrative Procedure Controls. 17.2A.6.7 MItft hl The control of documents shall app L e?!rtcords) ~ deli ed in Section 17.2A.17.

{M U b 17.2A.7 CONTROL OF PURCHASED MATERIAL, EQUI

$NlSERVICES 17.2A.7.1 l Measures shall be established and documented to assure that purchased items and services conform to the procurement F documents. These measures shall include provisions, as appropriate, for source evaluation and selection, objective evidence of quality furnished by the vendor, inspection at the i source, and examination of items upon delivery. I 17.2A.7.2 l Material, equipment, and services are purchased from vendors, l suppliers or contractors having an acceptable quality assurance i program which is consistent with applicable regulatory requirements and design basis or other appropriate measures shall be defined to assure quality. The EER Department Quality Assurance Division is responsible for evaluation of suppliers as described in Section 17.28.7. Procurement of items or services from other than " Evaluated Suppliers" shall be controlled and shall have the concurrence of the Superintendent, OA Division or his alternate for establishment of procurement requirements to assure the quality of the product. l O l l 17.2A-19 Rev. 46, 03/86 i L

LGS FSAR 17.2A.7.3 Measures for evaluation and selection of p.ocurement sources include the use of historical quality performance data, source surveys or audits, or source qualification programs. Procurement documents include, as appropriate, inspection points to verify compliance with procurement specifications. Source inspection or audit shall be performed as necessary to assure the required quality of an item. Source inspection or audit may not be necessary when the quality of the item can be verified by review of test reports, inspection upon receipt, or other means. 17.2A.7.4 Where required by code, regulations or specification, documentary evidence that items conform to procurement requirements shall be available at the plant site prior to installation or use of such items. This documentary evidence shall be retained at the plant site and shall be sufficient to identify the specific requirements such as codes, standards, and specifications met by the purchased item. Where not precluded by other requirements, such documentary evidence may take the form of written certifications of conformance which identify the requirements met by the items, providing means are available to verify the validity of such certificates. J 17.2A.7.5 Receipt inspections shall be performed to verify that material components or parts received conform to the purchase order requirements. Receipt inspection shall be performed by personnel who have access to the pertinent procurement documents and who have an understanding of the technical and quality requirements of the procurement document. Responsibility for receipt inspection shall be delineated in Administrative Procedures. l l l Rev. 46, 03/86 17.2A-20

LGS FSAR O Receipt inspection shall include, as appropriate, visual examination of physical properties, determination and identification of marking or labeling, and review and inspection of quality assurance documentation to verify conformance with the purchase order specifications and requirements. Control and identification status of the receipted material, parts, or components shall be accomplished in accordance with Administrative Procedures. IDENTIFICATIONANDCONTROLOFMATERIdLS,(79 59 i PARTS 17.2A.8 COMPONENTS -{ % b 17.2A.8.1 Measures shall be established and documented for the identification and control of materials, parts, and components including partially fabricated sub-assemblies. These measures shall provide for assuring that only correct and accepted items are used and installed, and relating an item of production O (batch, lot, component, part) at any stage, from initial receipt through fabrication, installation, repair or modification, to an applicable drawing, specification, or other pertinent technical document. Physical identification shall be used to the maximum extent practicable. Where physical identification is either impractical or insufficient, physical separation, procedural control, or other appropriate means shall be employed. Identification may be either on the item or on records traceable to the item, as appropriate. Where identification marking is employed, the marking shall be clear, unambiguous and indelible, and shall be applied in such a manner as not to affect the function of the item. Markings shall be transferred to each part of an item when subdivided and shall not be obliterated or hidden by surface treatment or coatings unless other means of identification are substituted. When codes, standards or specifications require traceability of materials, parts or components to specific inspection or test records, the procedures shall be designed to provide such traceability. O 17.2A-21 Rev. 46, 03/86

LGS FSAR 17.2A.8.2 Measures shall be established to identify and control materials ] (including consumables), parts or components in accordance with written procedures and instructions and shall apply to the fabrication, storage (including shelf life), and installation or use of the materials (including consumables), parts or components. Consumables, as addressed above, include, but are not limited to, weld filler material, lubricants, chemicals, reagents, and fuels that impact on safety-related equipment. 17.2A.8.3 The identification and control of materials, parts or components associated with design change activities shall be delineated in Administrative Procedures and shall cover such items as traceability to specifications, purchase orders, quality assurance documentation, fabrication and installation inspection and functional verification tests prior to use or placement in operation. 17.2A.9 CONTROL OF SPECIAL PROCESSES 17.2A.9.1 Measures shall be established and documented to assure that special processes, including welding, heat treating, chemical cleaning, coating, and nondestructive examination, are accomplished under controlled conditions in accordance with applicable codes, standards, specifications, criteria and other special requirements, using qualified personnel, equipment and procedures. Special processes are those that require interim in-process controls in addition to final inspection to ensure quality. Qualification of personnel, procedures, and equipment shall comply with the requirements of applicable codes and standards. Documentation shall be maintained for currently qualified personnel, processes, or equipment in accordance with the requirements of pertinent codes and standards. For special processes not covered by existing codes or standards, or where item quality requirements exceed the requirements of established codes or standards, the necessary qualifications of personnel, procedures, or equipment shall be defined. ll l Rev. 46, 03/86 17.2A-22

LGS FSAR [ gpg$ $ #S"fQ ^ ' - g mx ? tO. i \\1 W within the Company, and outside consq(fon'withiotherfdepartments The Maintenanc' Division, in conjunc ~ nece'agary, is responsiblefordevelopmentofspecia.j(Ntalwhe process" bcN Ms welding, heat treating, and nondestructive examination e5 under the 00A Program. These processes, the equipment u d the personnel implementing them shall be qualified. 17.2A.9.3 Heasures shall be established to control special processes, the equipment used, and the personnel implementing them in accordance with written procedures, instructions and drawings. Review and approval of special process procedures shall be accomplished in accordance with Administrative Procedures. Special instructions, procedures and drawings shall be furnished in accordance with applicable codes, standards, specifications, criteria, and other supplementary requirements. Special (~'/i processes may be reviewed by cognizant PECO personnel or outside consultants. x_ 17.2A.9.4 Certification of welders performing activities under the EP 00A Program shall be kept current through records of qualifying tests, recording of welds on current work, retraining and qualifying for specialty work in accordance with Maintenance Division Administrative Procedures. 17.2A.9.5 l The nondestructive examination procedures for the In-Service Inspection shall be written in accordance with applicable codes, standards and specifications. l NDE procedures shall require that personnel performing these examinations be qualified in accordance with the recommendations of the American Society for Nondestructive Testing Practice No. SNT-TC-1A, " Recommended Practice for Nondestructive Testing s Personnel Qualification and certification." l 17.2A-23 Rev. 46, 03/86 J

l LGS FSAR 17.2A.9.6 Results of special processes performed shall be documented, in accordance with approved instructions and procedures. l 17.2A.9.7 The OA Division Auditing and Quality control programs provide assurance that the qualification of special processes, the equipment used, and the qualifications of personnel are satisfactorily performed. 17.2A.10 INSPECTION 17.2A.10.1 A program for inspection of activities affecting quality shall be established and executed by the organization performing the activity to verify conformance to the documented instructions, procedures, and drawings for accomplishing the activity. Inspection activities to verify the quality of work shall be performed by persons other than those who performed the activity being inspected. Such persons shall not report directly to the immediate supervisors who are responsible for the work being inspected. The inspection programs for modifications and non-routine or major maintenance work shall be accomplished by personnel independent of the group or individual performing the work. Examinations, measurements, or tests of items processed shall be performed for each work operation where necessary to assure quality. A program for the inspection of quality related activities is established through administrative and implementing procedures to verify conformance with applicable procedures, instructions and drawing requirements. The preparation and control of procedures, instructions and drawings are in accordance with Administrative Procedures. l Rev. 46, 03/86 17.2A-24

1 LGS FSAR j 17.2A.10.2 If inspection of processed items is impossible or disadvantageous, indirect control by monitoring of processing methods, equipment, and personnel shall be provided[. Bothr@ trol inspection and process monitoring s gir6fided hsn jicon is inadequate without both. J 17.2A.10.3 If mandatory inspection hold points, which require witnessing or inspecting and beyond which work shall not proceed are required, the specific hold points shall be indicated in appropriate procedures. Such inspection shall be documented prior to the continuation of work beyond the designated hold point. The procedures shall include the characteristics to be inspected, a description of the method of inspection, acceptance / rejection criteria, a description of necessary measuring and test equipment, including appropriate accuracy requirements, and the O identification of the individual or group responsible for inspection. Satisfactory completion of inspection points shall be documented by a qualified individual and shall be included in the documentation associated with the performance of the work. Verification of equipment operability following maintenance and modification work shall be accomplished, along with inspection of the work area for safety, housekeeping, cleanliness, and health physics practices. 17.2A.10.4 Personnel performing Quality Control inspections shall be qualified in accordance with applicable industry standards and company training programs. Certifications of inspector qualifications shall be maintained in accordance with Administrative Procedures. OV 17.2A-25 Rev. 46, 03/86

LGS FSAR 17.2A.10.5 The code-authorized inspector shall ensure that the ASME B&PV Code inspections are performed in accordance with written approved procedures and accomplished by qualified personnel in accordance with ASME Code requirements. 17.2A.10.6 A program for required in-service inspection of completed systems, structures, and components shall be planned and executed by or for the organization responsible for operation of the plant. 17.2A.10.7 EP OA Division shall perform surveillance of selected quality related " work-in-progress" activities commensurate with the importance of such activities to verify that certain aspects of the Quality Assurance Program are performed adequately and in compliance with program and procedural requirements. Procedures shall be selectively reviewed, as appropriate, in the course of EP OA Audits and Surveillances, and Quality control Monitoring, Inspections, and Reviews to ensure that necessary inspection points are included and that a mechanism is provided for the documentation of inspection results. l 17.2A.10.8 Documented inspection results will be evaluated and their acceptability determined by qualified individuals. Evaluation beyond that given by inspection level personnel shall not normally be required for go/no-go and pass / fail type inspections. l 17.2A.10.9 If individuals performing inspections are not part of the OA organization, the OA Division will ensure through audits and surveillances, monitoring, and inspections that the inspection procedures, personnel qualification criteria, and independence lh from undue pressure, such as cost and schedule, are acceptable. Rev. 46, 03/86 17.2A-26

LGS FSAR rn 17.2A.11 TEST CONTROL nt T I 7 g? ?X:.Y : A..' :lk W kk y[kh 17.2A.11.1 A test program shall be established to ensure t 11 testing required to demonstrate that the item will perform satisfactorily in service is identified and documented, and that the testing is performed in accordance with written test procedures which incorporate or reference the requirements and acceptance limits contained in applicable Technical Specifications and design documents. The test program shall cover all required tests, including, as appropriate, qualifications tests, post-maintenance or modification tests, and operational surveillance tests to verify continued satisfactory performance during operation. The program for the control of testing shall be established in accordance with Administrative procedures. 17.2A.11.1.1 Heasures shall be established such that when an activity involves breaching a pressure retaining item, the quality of the work can be demonstrated through a functional test. The functional test shall be performed by individuals other than those who performed or directly supervised the work, but can be from within the same group. 17.2A.11.2 Test procedures shall include provisions for assuring that prerequisites for the given test have been met, that adequate instrumentation is available and used, and that necessary monitoring is performed.. Prerequisites include such items as calibrated instrumentation, appropriate equipment, trained personnel, condition of test equipment and the item to be tested, suitable environmental conditions, and provisions for data acquisition. Test Results shall be documented. Test procedures or instructions shall include or reference requirements for the evaluation of test results when an evaluation is appropriate. Evaluation beyond that given by testing personnel is not normally required for go/no-go and pass / fail type tests. O 17.2A-27 Rev. 46, 03/86

LGS FSAR Unsatisfactorily test results shall be documented as required by procedures and corrective action shall be taken in accordance with Administrative Procedures. 17.2A.ll.3 The Technical Specifications establish the requirements for the safe operation of the plant, including provisions for periodic and non-periodic tests and inspections of various structures, systems, and components. Periodic tests are those test delineated in the surveillance testing activity and non-periodic tests are those proof tests performed following modifications or major maintenance. 17.2A.11.4 Overall control of tests affecting plant operations shall be accomplished by Shift Operations personnel to assure that testing of components, systems and instruments do not adversely affect the safe operation of the plant. 17.2A.11.5 In addition to the above testing program, an In-Service Inspection Program shall be developed and implemented to assure that plant components perform satisfactorily in service. The program shall include baseline examinations and periodic examinations in accordance with Technical Specifications. 17.2A.12 CONTROL OF MEASURING AND TEST EQUIPMENT 17.2A.12.1 Measures shall be established and documented to assure that tools, gages, instruments, and other inspection, measuring, and testing equipment and devices used in activities affecting quality are of the proper range, type, and accuracy to verify conformance to established requirements. To assure accuracy, inspection, measuring, and test equipment shall be controlled, calibrated, adjusted, and maintained at prescribed intervals or prior to use against certified equipment having known valid relationships to nationally recognized standards. If no national standards exist, the basis for calibration shall be documented. l Rev. 46, 03/86 17.2A-28

LGS FSAR This requirement is not intended to imply a need for special i calibration and control measures on rulers, tape measures, l levels, and such other devices, if normal commercial practices provide adequate accuracy. 17.2A.12.2 The method and interval of calibration for each item shall be defined and shall be based on the type of equipment, stability characteristics, required accuracy, and other conditions affecting measurement control. Special calibration shall be performed when accuracy of the equipment is suspect. When inspection, measuring and test equipment are found to be out of calibration, an evaluation shall bermade and documented of the validity of previous inspection or. test results and of the acceptability of items previously inspect </d or tested. If any inspection, measuring, or test equipment is consistently foup(dpto be out of calibration, it shall be repaire rreplacedff dj! a ^ U " " hi$d8 17.2A.12.3 ng +p U !O t Reference standards used for calibrating measur hdbest equipment should have an accuracy level, acceptable ' calibration ranges, and precision that are better than those required of the measuring and test equipment. When this is not possible, reference standards with the same accuracy may be used if they can be shown to be adequate for the requirements and if the basis of acceptance is documented and authorized by responsible management. l The accuracies of measuring and test equipment and the reference standards shall be chosen such that the equipment being calibrated can be calibrated.and maintained within the required tolerances. Calibration shall be perforacd.with standards and calibrated test equipment that has known valid relationships to nationally recognized standards or to physical constants. When national standards do not exist, the basis for calibration shall be documented in accordance with procedures. Records shall be maintained and equipment suitably marked, or O otherwise controlled, to indicate calibration status. Such records shall be traceable and retrievable. 17.2A-29 Rev. 46, 03/86 J -r --...---m. .-m-

LGS FSAR Calibration of measuring and test equipment should be against reference standards that have an accuracy of at least four times the required accuracy of the equipment or, when this is not possible, has an accuracy that assures the equipment being calibrated will be within required tolerance and that the basis of acceptance is documented and authorized by responsible management. 17.2A.13 HANDLING, STORAGE, AND SHIPPING 17.2A.13.1 Measures shall be established and documented to control handling, storage, and shipping, including cleaning, packaging and preservation of material and equipment in accordance with established instructions, procedures, or drawings, to prevent damage, deterioration and loss. When necessary for particular items, special coverings, special equipment, and special protective environments, such as in,ert gas atmosphere, specific moisture content levels, and temperature levels shall be specified, provided, and their existence verified. O 17.2A.13.2 Special handling tools important to nuclear safety shall be inspected end tested in accordance with written procedures and at specified times, to verify that the tools and equipment are adequately maintained. 17.2A.13.3 Packaging requirements shall be delineated, as necessary to avoid deleterious effects of shock, vibration, physical damage and protection against environments. Shipping requirements shall be delineated, as necessary, to provide adequate protection during loading and transit. Labeling requirements are to be applied in a manner that is clearly visible and remain legible to specify special controls or handling instructions. O Rev. 46, 03/86 17.2A-30

LGS FSAR O 17.2A.14 INSPECTION, TEST, AND OPERATING STATUS 17.2A.14.1 Procedures shall be established and documented to identify t inspection, test, and operation status. Such procedures shall provide means for assuring that required inspections and tests i are performed and that the acceptability of items with regard to inspections and tests performed is known throughout procurement, installation, and operation to preclude inadvertent bypassing or altering the sequence of such inspections and tests. (Bypassing or altering the sequence of such inspections and tests should be subject to the same controls as the original review and approval.) Nonconforming items shall be clearly identified. Bypassing of, or deviation from,' required inspections, test, or operations defined in drawings and installation or test procedures shall be controlled by procedures. In general, approval to bypass or deviate shall require the same approvalvas the original requirement unless other provisions-are':specili'ed{l lb W " p,m 17.2A.14.2 p The inspection and test status of items shall b t ned through the use of status indicators such as physical location, tags, markings, shop travelers, stamps, or inspection records. The measures shall provide for assuring that only items that have passed the required inspections and tests are used, installed, or operated. These measures shall include procedures for control of status indicators, including the authority for application and I removal of tags, markings, labels, and stamps. P 17.2A.14.3 Measures shall also provide for indicating the operating status of systems and compcnents of the nuclear power plant, such as by tagging valves and switches, to prevent inadvertent operation. The operating status of components under test or inspection shall be indicated and controlled through the use of the handbook for permits and blocking, procedure check lists, or logs to prevent inadvertant use. ) l l 17.2A-31 Rev. 46, 03/86

LGS FSAR 17.2A.14.4 Defective material, parts, or components shall be promptly identified, tagged, and recorded or otherwise controlled to indicate operating status of such equipment and to prevent its inadvertant use. 17.2A.14.5 Implementation of these measures shall be verified through the EP OA Division Auditing and Quality Control Programs conducted in accordance with the 00A Plan. These activities shall ensure that the required inspections and tests are procedurally controlled as required by the EP 00A Plan. 17.2A.15 NONCONFORMING MATERIALS, PARTS, OR COMPONENTS 17.2A.15.1 Measures shall be established and implemented to control materials, parts, or components which do not conform to requirements to prevent their inadvertent use or installation. The measures established shall include, as app ~opriate, r administrative and/or implementing procedures for the following functions for nonconforming materials, parts, or components. a. Identification. As a guideline, control of nonconforming items by tagging, marking, or other means of identification is acceptable where physical segregation is not practical, although physical i segregation and marking are preferred. b. Segregation where necessary and possible; otherwise, identification will serve this function. c. Disposition covering: 1. Restoration to conforming status. Repaired and reworked items shall be reinspected in accordance with applicable procedures, or Rev. 46, 03/86 17.2A-32

LGS FSAR 2. Replacement with conforming material, or 3. Acceptance for interim use until replaced. Such l measures shall provide assurance that the item is identified as nonconforming and controlled. The measures shall require documentation verifying the acceptability of nonconforming items which have the disposition of " repair" or "use as is". A description of the change, waiver, or deviation that has been accepted shall be documented to record the change and denote the as-built condition. d. Notification to station management and other responsible j organizations of equipment malfunctions or deviations. These notifications may be either oral or written form ) of an abnormal occurrence or maintenance request form, l as appropriate. The notification system shall include provisions for initial and follow-up information until the item is finally dispositioned. O osition 6f The responsibility and authority for the disp?[ e. nonconforming items shall be defined for each r respo'nsible organization. g aniE' \\ eh' y f. Documentation of each item from at iddEt on to final disposition. 17.2A.15.2 Nonconforming materials, parts, or components identified by EP QA Division personnel shall be reported to Station Management in accordance with applicable procedures. i 17.2A.15.3 i PECO shall report abnormal occurrences and unusual events to the U.S. NRC as required by NRC Regulations and LGS Technical l Specifications. i i O 17.2A-33 Rev. 46, 03/86 4 e - e n-ew ww er ,.me,,,-y.,-, ee--.,,wmee,,m.n-,,-.,w-g.,..-,,-,wme,,w,---m.,,,.

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f LGS FSAR 17.2A.15.4 It is PECO's policy and intent that nonconforming materials, parts, or components not be installed in LGS.

Where technical adequacy is demonstrated to PECo's satisfaction, use of some nonconforming materials, parts, or components may be permitted. When this is done, a complete record shall be available l throughout the life of the material, part, or component. In no case will use of nonconforming materials, parts, or components be permitted if a hazard to the health and safety of the public could result from their use. Administrative Procedures shall delineate acceptance and approval mechanisms for permitting use of nonconforming materials, parts, or components. 17.2A.15.5 Vendors supplying materials, parts, or components are required to notify PECO of nonconformance to the procurement document requirements and to obtain approval from PECO prior to disposition. 17.2A.16 CORRECTIVE ACTION 17.2A.16.1 Measures shall be established to ensure that conditions adverse to quality are promptly identified and corrected. Conditions adverse to quality are failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformance to specified requirements. The measures established shall include the following: In cases of significant conditions adverse to quality, a. the cause of the condition shall be determined and documented, and corrective action taken and documented to preclude recurrance. b. Reports to appropriate levels of management of the significant condition adverse to quality and documentation of such reports. O Rev. 46, 03/86 17.2A-34

LGS FSAR A 17.2A.16.2 Administrative Procedures shall require that modification and repair procedures include the reworking of components, systems, or structures in accordance with original specifications, instruction manuals, instructions, prints, and codes and o standards. Appropriate testing and inspection requiremdritsfshall beincludedtoverifyacceptabilityoftherepairs(or,}9.6&g Y' modifications. 4JC i ; , *Qd 17.2A.16.3 ( ij b The responsibility for the above is assigned t LGS staff 4 members responsible for the various activities. 17.2A.16.4 The EP OA Division, through its Auditing and Quality control i . Programs, may identify conditions which require corrective O action. Such conditions shall be reported to responsible management for corrective action in accordance with applicable i procedures. 17.2A.16.4.1 Dependent upon factors, such as the nature of the deficiency, the cause, and the corrective action taken, the EP QA Division shall follow-up corrective action of deficiencies identified by the EP OA Division Auditing and Quality Control Programs to determine l the adequacy and effectiveness of such action. l 17.2A.16.4.2 The status of nonconformances or noncompliances identified by the EP OA Division as a result of the Auditing and Quality Control Programs shall be reported to the Manager - Nuclear Production, I and Vice President - Electric Production Department periodically. O 17.2A-35 Rev. 46, 03/86

l LGS FSAR 17.2A.16.5 Corrective action performed in response to an item identified by the EP QA Division Auditing Program shall have the documented concurrence of the EP QA Division for the adequacy of the corrective action. 17.2A.16.6 Procedures shall be established to ensure that safety-related structures and equipment nonconformances are controlled. These procedures shall include the following: Identify those individuals or groups who shall authorize a. the corrective action. b. Ensure that the DC Organization that has responsibility for the job performs a review of the planned corrective action. G c. Document the cause of the nonconformance, if it can be identified. d. Identify and document, if possible, the root cause. e. The appropriate staff engineer shall review the corrective action and equipment history to determine equipment performance trends, to identify repetitive failures and to adjust, if applicable, the preventive maintenance program. The EP QA Division shall verify through the Auditing or Quality Control Programs that the above controls are adequate. O Rev. 46, 03/86 17.2A-36

'g LGS FSAR 4 i 's s nt[ M 17.2A.17 QUALITY ASSURANCE RECORDS Gy) - f'\\. 4 f j \\p

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s 17.2A.17.1 u> V Sufficient records shall be maintained in accor nce with Administrative and implementing procedures to provide documentary evidence that activities affecting quality are performed adequately and in compliance with the Quality Assurance program. The requirements shall include collection, filing, storing, maintenance, and disposition of records that are required by the i EP OOA Plan and by other codes, standards, specifications, or j regulatory requirements. QA records shall include operating logs, maintenance and modification procedures, including related inspection results, reportable occurrences, and other records required by technical specifications. The procedures to be employed to perform the required activities shall be planned and documented. 17.2A.17.2 The significance of the event covered by a record type and the contribution of the record to the ability to reconstruct significant events shall be considered in establishing retention periods. Retention periods shall satisfy applicable statutory requirements. l 17.2A.17.3 Storage requirements for the maintenance, preservation, and protection of records from their completion, through submittal into and processing in the Nuclear Records Management System shall be established. l The records shall be stored in predetermined locations as necessary to meet the requirements of applicable standards, codes, and regulatory agencies, 17.2A.17.4 Applicable design specifications, procurement documents, test procedures, operational procedures or other documents shall ,( specify the quality records to be generated. All such records 17.2A-37 Rev. 46, 03/86 t

f LGS FSAR shall be legible, filled out to "e extent required by procedure and adequately identifiable to .1a item or activity involved. The applicable quality records shall be considered valid only if stamped, initialed, signed, or otherwise authenticated and dated by authorized personnel. These records may be either the original or a reproduced copy and shall be submitted to the LGS Document Administration Center for inclusion in the Nuclear Records Management System. 17.2A.17.5 Types of quality records with minimum retention periods are listed in LGS Technical Specifications. It should be recognized that the nomenclature of these records may vary. For records not listed in the Technical Specifications, the type most nearly describing the record in question should be followed with respect to its retention period. l17.2A.17.6 O The QA Division and other organizations responsible for record control are defined in the administrative and implementing procedures. 17.2A.18 AUDITS l 17.2A.18.1 l l l Compliance with the requirements and guidance for establishing and implementing the Electric Production Quality Assurance Program is assured through the EP OA Division auditing program. i The operation covered by this auditing program include designing, purchasing, fabricating, handling, shipping, storing, cleaning, l erecting, installing, inspecting, testing, modifying, and maintaining LGS Q-listed structures, systems, and components. In addition, audits are performed on non-Q activities that will enhance operational safety, as determined by Department Management. l 0 Rev. 46, 03/86 17.2A-38

LGS FSAR When corrective action measures are indicated, re-audits of applicable areas shall be conducted to assure implementation and effectiveness of the corrective actions. 17.2A.18.8 Audits performed under the cognizance of the Nuclear Review Board are discussed in Section 13.4. 17.2A.18.9 W Themeasuresimplementingtheauditingprogramshfil'.be,kY.$b.pdefJ c3 s in procedures contained in the EP Quality _ Assurance ~ Division Procedures and Instructions Manual., p, t.i 2 - ,g e " b # f:g i 17.2A.18.10 The auditing program shall be periodically reviewed and revised as necessary to assure that coverage and schedule reflect current activities. O 17.2A-41 Rev. 46, 03/86

LGS FSAR 17.2A.18.2 The EP QA Division auditing program shall consist of: l a. Audits - Documented. activities performed in accordance with ANSI N45.2.12 as described in Appendix 17.2A.II. b. Surveillances - Documented activities identicak t8 ; Audits except that no formal audit plan andya&dity?' checklist are generated and no exit interf1W is',y%> conducted if no noncompliances are ide'ntified ?> Surveillances are normally init ated(onish' ort;,otice based on plant conditions a nelnde"obsekvation of work in process. TU 17.2A.18.3 The Superintendent, EP QA Division is responsible for the planning, performance, reporting, and follow-up of the auditing O program of the various aspects of the EP OQA Plan to determine compliance with the elements of, and effectiveness of the EP OOA Plan. 17.2A.18.4 ' Audits and surveillances shall be peEformed in accordance with written procedures to confirm that the OOA Program is implemented in accordance with documented instructions, procedures and drawings. The results of the auditing program shall be documented by the Superintendent, EP QA Division and distributed to appropriate levels of management having responsibility in the area audited and Department management 17.2A.18.5 . Audits shall be regularly scheduled on the basis of the status and importance of the activities. The following activities of the Quality Assurance program shall be audited at least every two O years: Training, Health Physics and Chemistry, Fuel /Invessel Material, Shift Operations, Surveillance Testing, Maintenance of I 17.2A-39 Rev. 46, 03/86

LGS FSAR I Instruments, In-service Inspection, Maintenance - Electrical and Mechanical, Stores and Purchasing, Modifications, Radioactive Waste / Material and Plans. The Plan activity encompasses the LGS Emergency Plan, Physical Security Plan, Fire Protection Plan, and Radiological Environmental Monitoring Program. The LGS Emergency Plan and Physical Security Plan are audited annually. Regularly scheduled audits may be supplemented by unannounced or unscheduled audits or surveillances as determined by the Superintendent, EP OA Division. 17.2A.18.6 Audits and surveillances shall be performed by personnel from the EP Ouality Assurance Division, who are independent of any direct responsibilities for the performance of activities which they will audit. The EP OA Division may request assistance of personnel from other disciplines who are independent of areas being audited. The Superintendent, EP OA Division shall establish the auditing program personnel qualifications and the requirements for the use of technical specialists to accomplish the auditing of the quality assurance program. Personnel shall be selected for quality assurance auditing assignments based on experience or training which establish that their qualifications are commensurate with the complexity or special nature of the activities to be audited. In selecting personnel for auditing assignments, consideration shall be given to special abilities, specialized technical training, prior pertinent experience, personal characteristics and education. 17.2A.18.7 Audit and Surveillance procedures shall require that nonconformances which are identified be documented in sufficient detail to assure that required corrective action enn be effectively carried out by the audited organization. Corrective action may be recommended, as appropriate, by the Superintendent, EP OA Division. O l Rev. 46, 03/86 17.2A-40

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3 \\\\ LGS FSAR TABLE 17.2A.I-1 (Page 1 of 3) 10 CFR, Part 50 APPENDIX B CRITERION MATRIX 10 CFR, Part 50 Appendix B Criterion edures 1 234 56789 10 11 12 13 14 15 16 17 18 arntion and Control of X XX X (2) hictrative Procedures lt Operations Review XXX X X X f a:76 ,s M itt03 i f *,* [ W} %' ' : l 7,e# r. 1 Xs '.X. a X 1t-2 ) p t cnd shift Operations XX XX X X 9 %$ [i " J X "Y 'Q , O ' h , y' g. K (2) 03 of Safety Related XX X X WW t 4 ( J g ' ment for Maintenance g

i. Y rary Modifications XXX XX X

X X (2) ol of Plant XXXXXXX X X X X X X X (2) ications ol of In-plant Work XX X XX X X X X X X (2) istration of the XXX XX X X X X X (2) pntivoMaintenance pam istration of the XX XX X X X X (2) illance Testing Program istration of Plant XX X (2) ds rement XXXXXXXX X X X X X (2) .istration of Plant XX X X (2) ity Progarm ration and Control of XX XX X X X X X X (2) ' nance Procedures }rationandControlof XX XX X (2) ncy Procedures "y APERTURE ation and Control of XX XX x (2> i e "" CARD hrationandControlof XX XX X (2) al Plant Procedures gg l

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- i TI APER M CARD Also Avs1We @

Aperture Card Rev. 46, 03/86 l1 260 sons 2-os

LGS FSAR O Appendix 17.2A.II l i ELECTRIC PRODUCTION DEPARTMENT APPLICATION OF INDUSTRY STANDARDS AND NRC REGULATORY GUIDES Philadelphia Electric Company Electric Production Department QualityAssuranceProgramwillfollowtheguidancecontaineding9( NRC Regulatory Guides and the requirements of Industry Standards,' as described below. When a Regulatory Guide endorses an Industry;;&52 ~ Standard, compliance with the recommendations offarguidei % d ' indicates compliance with the requirements he 'st'andard;,and Mnt' 71referen'cednin i those guidelines modified by the guide. Do s afsss$df\\W)u/ ^ an ANSI Standard are excluded unless they ar separately. g% a. Reculatory Guide 1.30, August 1972, " Quality Assurance Requirements for the Installation, Inspection, and Testing of i Instrumentation and Electric Equipment" Endorses ANSI N45.2.4 - 1972. i l PECO shall comply with Regulatory Guide 1.30, August 1972, and ANSI N45.2.4 - 1972 for those activities occurring during / the operational phase that are comparable in nature and extent, as determined by the Manager - Nuclear Production and Superintendent - QA, to related activities occurring during l the initial design and construction phase, except for the following alternates: 1 1. ANSI N45.2.4, Section 1.1, Scope - PECO's alternate to classification of Class 1 and IE electric power, instrumentation, and control equipment is to apply the requirements of this standard to PECO "Q-listed" items. (Those instruments, equipment and systems that prevent or mitigate the consequences of postulated accidents I that coula cause undue risk to the health and safety of the public.) 2. ANSI ~N45.2.4, Section 3, Preconstruction Verification - Subsection (3) requires the checking of records of i protective measures maintained during storage for conformance to storage requirements. ANSI N45.2.2 - i 1978, Section 6.4, Control of Items in Storace requires inspections and examination 3uring tee storage period. The responsibility within PECO for these inspections rests with the Stores Division. Compliance with these requirements for checking of records is ensured through the Auditing and Quality Control Programs conducted by EP Quality Assurance Division Personnel along with the monitoring of Stores Division Activities by Stores Division Supervision. 17.2A.II-1 Rev. 46, 03/86

LGS FSAR O 3. ANSI N45.2.4, Section 7, Data Analysis and Evaluation - A program for processing, reviewing, and analyzing electrical equipment and instrumentation inspection and test data for acceptability is provided in the administrative procedures which govern the repair, maintenance, and testing of electrical equipment and instrumentation. Maintenance is controlled through the use of a work request form that has provisions for cognizant personnel sign-off after completion of the work. Functional testing and calibration procedures include provisions for review, analysis of data, and approval by signature of cognizant personnel, b. Reculatorv Guide 1.33, Revision 2, February 1976, " Quality Assurance Program Requirements (Operations)." Endorses ANSI N18,7 - 1976/ANS 3.2. PECO shall comply with Regulatory Guide 1.33 - Revision 2, February 1978 and ANSI N18.7 - 1976/ANS 3.2 except for the following clarifications or alternates: 1. Regulatory Guide 1.33, Section C.4 and ANSI N18.7 - 1976/ANS 3.2, Section 4.5, Audit Program - The audit program carried out by the EP Quality Assurance Division shall be performed in such a manner that individual activities of the EP OOA Plan are investigated in accordance with Paragraph 17.2A.18.5. This investigation shall consist of either audits or surveillances. See Section 17.2A.18. 2. Regulatory Guide 1.33, Section C.4.c and ANSI N18.7 - l 1976/ANS 3.2, Section 4.5, Audit Procram (second paragraph) - The word " performance" means the implementation of the training program, participation in the training program by individuals, and the comparison of documented qualifications with established requirements. Activities and records associated with confidential employee performance reviews and subjective evaluation of personnel capabilities are specifically excluded from the audit program. 3. Regulatory Guide 1.33, Section C.S.c and ANSI N18.7 - 1976/ANS 3.2, Section 5.2.4, Special Orders and Section 5.2.5, Temporary Procedures - The types of procedures described in these sections are not expected to be used at LGS. Administrative Procedures will specify mechanisms for temporary changes to existing procedures. Rev. 46, 03/86 17.2A.II-2

LGS FSAR O 4. ANSI N18.7 - 1976/ANS 3.2, Section 4.3, Independent Review Program - The description and activities of the Nuclear Review Board will be as specified in the LGS Technical Specifications. 5. ANSI N18.7 - 1976/ANS 3.2, Section 4.3.2.2, Meetino Frequency - The " period of initial operation" means "one year after fuel loading of Unit 1". 6. Deleted TI'1, e n ?'b g (-Af 0 \\$g a-3 O 7. ANSI N18.7 - 1976/ANS 3.2, Section 4.4, Review Activities of the Onsite Operatino Organization - The word " verify' does not imply review or certification by supervisory personnel of every day-to-day operating activity; rather, the performance of reviews of documents and logs and monitoring activities by supervisory personnel in accordance with station procedures and practices is considered to meet this requirement. 8. ANSI N18.7 - 1976/ANS 3.2, Section 5.2.1, Responsibi1ities and Authorities of Operatino Personnel - Item (4) is changed to read: " Ee responsibility to respond conservatively to instrument indications including the case in which the credibility of the indication is in doubt". This statement permits the operator to compare Control Room instruments and infer instrument error without proving it such as by calibration checks. 9. ANSI N18.7 - 1976/ANS 3.2, Section 5.2.2, Procedure O Adherence - The term " supervisor in charge of the shift" 17.2A.II-3 Rev. 37, 10/84 A

LGS FSAR O means either the Shift Superintendent or Shift Supervisor. 10. ANSI N18.7 - 1976/ANS 3.2, Section 5.2.6, Equipment Control (6th paragraph, last sentence) and Section 5.2.13.2 (4th paragraph) - In order to allow for action other than obtaining the original specified documentation, " disposition by proper authority" is the criteria for use of items which have been identified as nonconforming. 11. ANSI N18.7 - 1976/ANS 3.2, Section 5.2.6, Equipment Control (a.) Temporary modification (5th paragraph) - The need for independent verification of Temporary Hodifications will be determined on an individual basis considering the complexity and impact of the modification. (b.) (7th paragraph) requires " operating personnel" to place equipment in operation. Equipment may be placed into operational status by personnel not on the operating staff, such as instrument technicians. 12. ANSI N18.7 - 1976/ANS 3.2, Section 5.2.7, Maintenance and Modifications - The requirement concerning original design bases and requirements, material specifications, and inspection requirements is modified to permit approved alternate requirements which are subject to the design review process. 13. ANSI N18.7 - 1976/ANS 3.2, Section 5.2.7.1, Maintenance Procrams (a.) Emergency maintenance to 0-Listed equipment (work which must proceed immediately to correct a degraded condition) may be performed concurrent with procedure preparation and documentation of steps actually taken. Such maintenance may be performed with the authorization of designated personnel and subsequent procedure review by PORC Rev. 46, 03/86 17.2A.II-4 i

LGS FSAR O and approval by the Station Manager, or designated alternate. (b.) The cause of repetitive malfunctions should be determined; however, it is not practical,.aqd may not be possible, to determine the cause of?' ery malfunction. ef K y ,s % h, V a gg 14. ANSI N18.7 - 1976/ANS 3.2, Sect [Sn5/2.1:j0 Housekeeping p and Cleanliness Control g W'.Ti p9 Y.l (a.) Control measures to p vent co tion with foreign materials will be speci d in' Administrative Procedures and will include, as appropriate, access control. (b.) Second paragraph, first & second sentences are taken to mean: "Where needed to prevent contamination. 15. ANSI N18.7 - 1976/ANS 3.2, Section 5.2.11, Corrective Action - The Plant Operations Review Committee and/or he Independent Safety Engineering Group (ISEG) determines which items are "significant". 16. ANSI N18.7 - 1976/ANS 3.2, Section 5.2.12, Plants Records Management - Retention periods will satisfy statutory requirements for the record. The significance of the event covered by the record and the contribution of the record to the ability to reconstruct significant events will be considered in establishing retention periods. 17. ANSI N18.7 - 1976/ANS 3.2, Section 5.2.13, Procurement and Material Control - Item (1) - Administrative Procedures shall specify the means for control of procurement of commercially "off the shelf" items. The Administrative Procedures shall describe the receipt inspection, storage, and handling prior to installation and operation. Off-the-shelf (catalog) items are evaluated by qualified personnel for their intended use. The Administrative Procedure restricts the use of catalog items for only these evaluated applications. (- The purchase order shall require the vendor to notify the requisitioning organization of a change in an item described in the catalog. 17.2A.II-5 Rev. 46, 03/86

LGS FSAR O 18. ANSI N18.7 - 1976/ANS 3.2, Section 5.2.13.1, Procurement Document Control, (second sentence) - QA program requirements or alternate approved methods will be used to assure quality. Examples of alternates for suppliers without OA programs include: material analysis, sample testing, in-process inspection and monitoring, and design review by PECO. 19. ANSI N18.7 - 1976/ANS 3.2, Section 5.2.15, Review, Approval and Control of Procedures - The frequency of review of plant procedures is discussed in FSAR Section 13.5. 20. ANSI N18.7-1976/ANS 3.2, Section 5.2.17, Inspections - The results of inspections are not always subject to a further evaluation. For example, evaluation beyond that given by inspection - level personnel is not normally required for go/no-go and pass / fail type inspections. 21. ANSI N18.7 - 1976/ANS 3.2, Section 5.3, Preparation of ~~ Instructions and Procedures, (last sentence) - The clarification regarding emergency maintenance in item 13, above, applies. 22. ANSI N18.7 - 1976/ANS 3.2, Section 5.3.10, Test and Inspection Procedures, (first paragraph) - The clarification regarding test result evaluations in item 20, above, applies. 23. ANSI N18.7 - 1976/ANS 3.2, Section 5.3.10, Test and Inspection Procedures, (second paragraph, last sentence) - These procedural aspects will be included when appropriate. For example, "as-found condition" is not applicable to all test and inspection procedures. c. Reculatory Guide 1.37,' March 1973, " Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components of Water-Cooled Nuclear Power Plants." Endorses ANSI N45.2.1 - 1973. Decontamination and cleanup of radioactively contaminated systems and components are not 1..cluded in the scope of this response. Rev. 21, 06/83 17.2A.II-6

LGS FSAR O PECO shall comply with Regulatory Guide 1.37 - March 1973 and ANSI N45.2.! - 1973 for those activities occurring during the operational phase that are comparable in nature and extent, as determined by the Manager - Nuclear Production and the Superintendent - OA, to related activities occurring during the initial design and construction phase except for the following alternate: 1. ANSI N45.2.1, Section 3.2, Water Quality Requi'rements - PH measurements are not required for conductivl y values of 5 1 micromho/cm. PECO utilizes PH limlt.s) 5.2 to s 8.6 at 250 C, uncorrected for CO2,and mays. y conductivity. measurements in place?of%)ot I dissolved solids. A"p*1 'wM l k s 2. ANSI N45.2.1, Section 3 , Cla e flushing velocity may be as specified in o approved documents associated with the maintenance or modification, as well as procurement documents. 1 O/ d. Reculatory Guide 1.38, Revision 2, May 1977, " Qual ~ity Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Water-Cooled Nuclear Power Plants." Endorses ANSI N45.2.2 - 1972. i See discussion under ANSI /ASME N45.2.2 - 1978. e. Reculatory Guide 1.39, Revision 2, September 1977, " Housekeeping Requirements for Water-Cooled Nuclear Power Plants." Endorses ANSI N45.2.3 - 1973. j PECO shall comply with Regulatory Guide 1.39, September 1977 i and ANSI N45.2.3 - 1973 for those activities occurring during l the operational phase that are comparable in nature and extent, as determined by the Manager - Nuclear Production and Superintendent - OA, to related activities occurring during the design and construction phase except for the following i alternates: t 1. ANSI N45.2.3, Section 2.1, Plannino - Zone II ~ 1 g requirements for clean gloves, shoe covers, and head coverings will be determined by health physics personnel i I-17.2A.II-7 Rev. 42, 03/85 J r.-r~..,,%.~.4. .....,y ny.. >cc. ..,-._,ym, .-,m_-m _.m.m..-,y,, _,, _ - - _. _, - - -_ _ _ _.

LGS FSAR under the radiation protection program and specific requirements listed on the Radiation Work Permit for entry in Zone II areas. 2. ANSI N45.2.3, Section 2.1, Plannino - Material accountability for Zones II and III shall be controlled by procedural requirements, periodic inspections and surveillance of areas for acceptable housekeeping practices. Implementing procedures for activities such as maintenance and modifications require housekeeping and cleanliness inspections of areas and equipment to eliminate foreign materials that may have a detrimental effect. Post Maintenance or modification inspections for housekeeping and cleanliness shall be conducted and documented in accordance with administrative controls. 3. ANSI N45.2.3, Section 2.1 Plannino - Personnel accountability for Zone III will be controlled as 1 determined by the administrative controls for locked doors and radiation work permit requirements in lieu of specific access registers. O f. Reculatory Guide 1.58, Revision 1, " Qualification of Nuclear Power Plant Inspection, Examination, and Testing Personnel." Endorses ANSI N45.2.6 - 1978. Philadelphia Electric Company shall comply with Regulatory Guide 1.58, Rev. I and ANSI N45.2.6-1978 except for the following clarification and alternates: 1. Regulatory Guide 1.58, Revision 1, section C.1, and ANSI N45.2.6-1978, subsection 1.2, states that the standard applies to " personnel who perform inspections, examinations, and tests." Philadelphia Electric Company personnel, who inspect equipment as part of plant maintenance, in other than a quality control function, and plant staff personnel (as defined in the Limerick Technical Specifications) who approve test procedures and tests results and direct or supervice the conduct of individual tests, will be qualified in accordance with ANSI /ANS 3.1-1978 in lieu of ANSI N45.2.6-1978. l 2. Deleted. O Rev. 46, 03/86 17.2A.II-8

LGS FSAR O 3. ANSI N45.2. ti-1978, subsection 3. 5, presents experience recommendations for candidates. Experience in l maintenance, modification, and operating activities is considered related experience because such experience, provides training in the safety aspects of the;fahil'ity. M h (?J 2 l g. Reculatory Guide 1.64, Revision 2gJunbl976k" Quin Assurance Requirement for the DeslignLof rNuclear ' owier Plants." IW" Endorses ANSI N45.2.11 - 1974. g I PECO shall comply with Regulatory Guide 1.64, June 1976, and ANSI N45.2.11 - 1974 for those Electric Production Department activities occurring during the operational phase that are 4 i comparable in nature and extent, as determined by the Manager - Nuclear Production and Superintendent - OA, to related activities occurring during the initial design phase with the i following clarification and alternates: Clarification - 1. Plant Design changes are categorized into Major and Minor Modifications. Design controls for Major Modifications which are delegated to the Engineering and i l Research Department are described in Section 17.2B. l Major Modifications are defined in LGS Administrative Procedures. 2. Minor Modifications are accomplished under the controls of plant administrative procedures in accordance with the LGS EP Ouality Assurance Plan. Alternate - Regulatory Guide 1.64, Regulatory Position C.2(1) - Design i verification may be performed by the designer's immediate supervisor under the following circumstances: l 1. When the supervisor is the only technically qualified individual 2. The need is individually documented and approved in advance by the supervisor's management 3. OA audits cover frequency and effectiveness of use of supervisors as design verifiers to guard against abuse. O 17.2A.II-9 Rev. 46, 03/86 l 1

LGS FSAR O h. Regulatory Guide 1.74, Revision 0, February 1974, " Quality Assurance Terms and Definitions." Endorses ANSI N45.2.10 - 1973. PECO shall comply with Regulatory Guide 1.74, Revision 0, February 1974 and ANSI N45.2.10 - 1973 except for the following alternate: The word " examination" also means an exercise to examine progress or status of knowledge or qualification. i. Regulatory Guide 1.88, Revision 2, October 1976, " Collection, Storage, and Maintenance of Nuclear Power Plcnt Quality Assurance Records." Endorses ANSI N45.2.9 - 1974. See discussion under ANSI /ASME N45.2.9 - 1979. j. Regulatory Guide 1.94, Revision 1, April 1976, " Quality Assurance Requirements for Installation, Inspection, and W Testing of Structural Concrete and Structure Steel During the Construction Phase of Nuclear Power Plants." Endorses ANSI N45.2.5 - 1974. PECO shall comply with Regulatory Guide 1.94, April 1976 and ANSI N45.2.5 - 1974 for those activities occurring during the l operational phase that are comparable in nature and extent, l as determined by the Manager - Nuclear Production and Superintendent - OA, to related activities occurring during the initial design and construction phase. l k. Regulatory Guide 1.116, Revision 0-R, May 1977, " Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems." Endorses ANSI N45.2.8 - 1975. PECO shall comply with Regulatory Guide 1.116, May 1977, and ANSI N45.2.8 - 1975 for those activities occurring during the operational phase that are comparable in nature and extent, as determined by the Manager - Nuclear Production and Superintendent - OA, to related activities occurring during the initial design and construction phase, except for the following alternates: Rev. 42, 03/85 17.2A.II-10

LGS FSAR \\_ / 1. ANSI N45.2.8, Section 2.2, Procedures and Instructions - FSAR Section 13.5 addresses compliance with ANSI N18.7 - 1976/ANS 3.2 and Regulatory Guide 1.33. These requirements provide adequate controls for the Procedures and Instructions addressed in this Section. \\ g% Q ^ 2. ANSI N45.2.8, Section 2.3, Results, PECO's\\c.ommitaSnt to ANSI 18.7 - 1976/ANS 3.2,provides'adeq'u' ate;qdi8ince for the documentation and revied'ofithe.res61ts of inspections and tests. { QU 3. ANSI N45.2.8, Section 3.4, Physical tion - PECO's response to ANSI N45.2.1, N45.2.2, and N45.2.13 provide adequate guidance and control for the requirement that mechanical items are in accordance with specified requirements and that the gaality has been maintained. 1. Reculatory Guide 1.123, Revision 1, July 1977, " Quality Assurance Requirements for Control of Procurement of Items and Services for Nuclear Power Plants." Endorses ANSI N45.2.13 - 1976. PECO shall comply with Regulatory Guide 1.123, July 1977, and i ANSI N45.2.13 - 1976 for those activities occurring during the operational phase that are comparable in nature and extent, as determined by the Manager - Nuclear Production and Superintendent - OA, to related activities occurring during the initial design and construction phase. 1 i m. Regulatory Guide 1.144, September 1980, " Auditing of Quality Assurance Programs for Nuclear Power Plants" endorses ANSI /ASME N45.2.12-1977. PECo shall comply with Regulatory Guide 1.144, September 1980, and ANSI /ASME N45.2.12-1977 with the clarification discussed in Item 1 under Regulatory Guide 1.33 and with the following alternates: 1. ANSI /ASME N45.2.12, Section 4.2.4, Audit Notification and Section 4.3.1, Pre-Audit Conference - Pre-Audit notification is given to plant management in an informal manner due to daily contact and communications between Quality Assurance Division personnel and plant p personnel. 17.2A.II-11 Rev. 42, 03/85

LGS FSAR O 4. ANSI /ASME N45.2.12, Section 4.4.6, Reportina - The audit report shall be issued with 30 working days after the post-audit conference. n. Reculatory Guide 1.146, August 1980, " Qualification of Quality Assurance P00 gram Audit Personnel for Nuclear Power Plants" Endorses ANS!/ASME N45.2.23-1978. Philadelphia Electric Company shall comply with Regulatory Guide 1.146, August 1980 Land ANSI /ASME N45.2.23-i978 except for the following alternate: 1. ANSI /ASME N45.2.23-1978, subsection 2.3, states requirements for qualification of auditors. In lieu of the stated requirements, PECo will qualify personnel in. accordance with requirements presented below. These alternate requirements will provide PECo with sufficient flexibility to qualify competent personnel with initial technical experience in a more effective manner. The proration of credits between initial experience requirements and additional experience gained as an assistant to a Lead Auditor ensures that highly qualified personne) will be available as audit personnel in a more timely fashion. Substitute the following for Paragraph 2.3.1 of ANSI /ASME N45.2.23-1978. 2.3.1 Education and Experience. The prospective Lead Auditor shall have verifiable evidence that a minimum of ten (10) credits under the following scoring system have been accumulated. 2.3.1.1 Education (4 credits maximum). Associate degrees from an cccredited institution score one (1) credit or if the degree is an engineering, physical l Rev. 46, 03/86 17.2A.II-12

~ i LGS FSAR O sciences, mathematics, or quality assurance, score two (2) credits or, a bachelor degree from an accredited instituti score two (2) credits or if the degree is in 1\\ $ l engineering, physical sciences, mathematics, orequalt assurance, score three (3) credits; in additioni one (1) credit for a master degree in engine,eyinbW l physical sciences, business management,( or quar 13p assurance from an accredited ins tjon7 g\\ z 2.3.1.2 a) Initial Experience Prior to Assignment (6 credits maximum). Technical experience in engineering, manufacturing, constrhetion, operation, maintenance, or quality assurance related to the t aforenentioned activities, score one (1) credit for each full year with a maximum of five (5) credits for this aspect of experience. If two (2) or more years of this experience have been in the nuclear field, score one (1) additional credit. i i 2.3.1.2 b) Additional Experience (after i assignment) (4 credits maximum). Experience in quality 1 assurance, score one (1) credit for each full year (2 ] credits maximum) or, o Experience in auditing, score two (2) credits for l each full year (3 credits maximum) or, Experience in nuclear quality assurance, score one (1) credit for each full year (3 credits maximum) or, l 1 Experience in nuclear quality assurance auditing, l score one (1) credit per every six months (4 credits maximum). l l 2.3.1.3 Other Credentials of Professional Competence (2 credits maximum). Certification of competency in engineering, science, or quality assurance specialities issued and approved by a State Agency, or l 17.2A.II-13 Rev. 46, 03/86 l

LGS FSAR O National Professional or Technical Society, score two (2) credits. 2.3.1.4 Rights of Management (2 credits maximum). The Lead Auditor's employer may grant up to one (1) credit for other performance factors applicable to auditing which may not be explicitly called out in this standard such as leadership, sound judgment, maturity, analytical ability, tenacity, and past performance, plus one (1) credit for satisfactory completion of Lead Auditor training program. I o. ANSI /ASME N45.2.2 - 1978 " Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants." i PECO shall comply with the requirements of ANSI /ASME N45.2.2 - 1978 except for the following alternates: 1. ANSI /ASME N45.2.2, Section 2.7, Classification of Items - Philadelphia Electric Co. does not classify items into the four (4) levels described in this standard. However, the specific guidance and recommendations which are appropriate to each class are applied to those items packaged, shipped, received, stored, and handled through the use of procedures, original specifications, instructions and drawings as applicable. 2. ANSI /ASME N45.2.2, Section 3, Packaging and Section 4, Shipping - Philadelphia Electric Co. utilizes the packaging and shipping requirements delineated in the original equipment specifications as part of our procurement requirements to suppliers or manufacturers, l Those requirements and recommendations of Sections 3 and l 4 are included in the original specifications as i appropriate for the item being procured. Receipt inspection activities are in accordance with Section 5 of this standard and are sufficient to identify packaging and shipping nonconformities. 3. ANSI /ASME N45.2.2, Section 6, Storace - Philadelphia Electric Co. does not classify items into four (4) levels for storage purposes as delineated in Section 6.1.2. Stored items are placed in limited access controlled areas, and are segregated with respect to the lh 0-list classification of the item (s). The specific Rev. 22, 07/83 17.2A.II-14

I LGS FSAR O QUESTION 260.1 Identify in more detail on organizational charts all the "onsite" and "offsite" organizational elements which function under the cognizance of the OA program (such as design, engineering, procurement, r.anufacturing, construction, inspection, test, instrumentation and control, nuclear engineering, operations, and maintenance). (SRP 17.1, 1A5)

RESPONSE

The Operation and Maintenance divisions of Limerick are part of the Electric Production Department, as shown in Figure 17.2-2. One division of the Electric Production Department is the Quality Assurance Division, as shown in Figure 17.2-3. The Maintenance Division is shown on Figure 17.2-4, with the details of the onsite group shown in Figure 17.2-5. The onsite Operations Group is shown on Figure 13.1-2. The Engineering and Research organization charts (Figures 17.2-11, 17.2-8, 17.2-12) show the branches, "onsite" (S) or (~') "offsite" (O), which function under the E&R OA program. All \\d onsite organizations are located at the Limerick construction site. Offsite organizations are located in PECo's Main,0ffice in i Philadelphia, with the exception of the Plymouth TestsiBrindh (TestingandLaboratoriesDivision)whichislocatedhi~nPippbuth , '[\\\\ 'y> Meeting, PA. C" n 4W Figure 17.2-15 is a functional QA/QC' e Q,'yDiagramsof0Qr izations l performing verification activities $'th'in)hth8-Elec Production Department and the Engineering and rc , and it outlines the approximate personnel affing f anizations involved in such activities at Peach Bottom a Limerick

Stations, l

l O j 260.1-1 Rev. 46, 03/86

LGS FSAR O b/ OUESTION 260.2 Describe the criteria for determining the size of the OA organization including the inspection staff. (SRP 17.1, IAS)

RESPONSE

The criteria that are being used to determine the size of the Limerick OA organizatior is based on the experience obtained from the startup and operations of the Peach Bottom Station. The Limerick site will have a core group of DA Division Auditors and OC Inspectors dedicated to the site. The Site Auditors will be augmented as required by the corporate auditors. The Site Auditors will be directed by a dedicated Site Supervisor. QC Engineers will also be dedicated to the site. The DC Inspection Staff for the Construction Division and the Testing and Laboratories Division will be on site as required. l When needed, OC Inspection Staffs will be augmented with qualified vendor personnel. The criteria that are being used to determine the site Radwaste QC Inspection and Receipt Inspection V("% will be based on the experience obtained from the operations of the Peach Bottom Station. ,e S 4 @:v v

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i 4 i i ) O 1 260.2-1 Rev. 46, 03/86 ,-.--.,----.w .-,_.._~%#w ..e,,.ve,--,wm--*-r,r--, - - -, - -,--w-rm,----m,--w-rv,%--,+.w%,,-.ym-,. r--w,-.-

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LGS FSAR ^ OUESTION 260.3 Describe those provisions which assure that verification of conformance to established requirements is accomplished by individuals or groups within the QA crganization who do not have direct responsibility for performing the work being verified. If l this function is performed by individuals other than the QA organization, then identify the organizational position and the OA/QC qualification of that position. (SRP 17.1, 1B2) 1

RESPONSE

1 Verificiation of conformance to established requirements is accomplished by members of the Construction Division, Maintenance Division, Testing and Laboratories Division, Limerick Operating i Shift Crew, and EP OA Division. l. All QC Inspectors are qualified to ANSI N45.2.6. All Auditors are qualified to ANSI N45.2.23. All NDE Inspectors are qualified to ASNT-TC-1A. l The following FSAR sections provide additional information on the above organizations. (O l Maintenance j p F, A g d; y,d Section 17.2.1.2.5.3.6. s. s e Construction p;$;2f 5}.Nj4 Section 17.2.1.3.4.3. j g Testino and Laboratories l l Section 17.2.1.3.5.3. Limerick Operatina Shift Crew f Section 13.1.2.19. EP Ouality Assurance l Section 17.2.1.2.3.

O 4

i 260.3-1 Rev. 46, 03/86

LGS FSAR \\ OUESTION 260.4 Describe those provisions which assure that persons and organizations performing OA functions have direct access to management levels which will assure the ability to: (SRP 17.1, IB3) a. Identify quality problems. b. Initiate, recommend, or provide solutions through designated channels, c. Verify implementation of solutions. Those persons and organizations with the above authority are identified and a description of how those actions are carried out is provided.

RESPONSE

The following FSAR sections provide the requested information: EP Ouality Assurance Division l Section 17.2.1.2.3.1. l E&R Ouality Assurance Division f l \\ g u,,)y ~ h ' j' Section 17.2.1.3.2. _. G ' s, e (f ,., o - 3 (gg 4 O 't 260.4-1 Rev. 46, 03/86 - ~.

LGS FSAR QUESTION 260.5 i Describe those provisions which assure that designated QA and QC personnel, sufficiently free from direct pressures for cost / schedule, have the responsibility delineated in writing to stop unsatisfactory work and control further processing, delivery, or installation of nonconforming material. (SRP 17.1, 1Bea)

RESPONSE

The following FSAR sections provide the requested information: l l OC OPERATIONS EP Ouality Assurance Division l Section 17.2.1.2.3.1 Construction m,' .i Section 17.2.1.3.4.3. O h s, W [: O 49flM S,j($,O. 3 l Testino and Laboratories l y ~ ( ta Section 17.2.1.3.5.3. O= OA OPERATIONS EP Ouality Assurance Division l Section 17.2.1.2.3.1. l i 2O j 260.5-1 Rev. 46, 03/86 4 i

LGS FSAR OUESTION 260.13 Describe those provisions which assure that the QA organization and the necessary technical organizations participate early in the QA program definition stage to determine and identify the extent QA controls are to be applied to specific structures, systems, and components. (SRP 17.1, 2B3)

RESPONSE

Limerick is currently staffed with Electric Production Quality Assurance Personnel, including a lead auditor and a quality engineer. Corporate QA and technical personnel are available for support when needed by the QA and technical site personnel. The Quality Assurance Plan for the operations phase of Limerick will describe how the QA and the necessary technical organizations are involved and to the extent the QA controls are to be applied to specific structures, systems, and components. Sections 17.2A.2.7, 17.2A.2.8, and 13.8 provide additional information. f[s \\ '.

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,9 ., e,71 R Y j,. iif \\ q., u fy*,&h 3Q O 260.13-1 Rev. 46, 03/86 m

i LGS FSAR OUESTION 260.15 j Provide a description that emphasizes how the docketed QA program i description, particularly the Regulatory Guides listed in i Appendix 17.2A.1 and 17.2B.1 of the SAR, will be properly carried out. (SRP 17.1, 2BS)

RESPONSE

The President of the Philadelphia Electric Company has issued a policy statement endorsing the OA Program for nuclear activities. Limerick OA Plan, Volume III (Operations Phase), Administrative Procedures, Implementing Procedures, and audits will provide for carrying out PECo commitments to ReguJatory Guides listed in Appendix 17.2A.II and 17.2B.II. The Limerick OA Plan, Volume IV, for the operations phase, in l conjunction with the implementing procedures will provide for 4 2 carrying out PECo commitments to the Regulatory Guides listed in Appendix 17.2B.II. ., C ~ ' i k@g' l de i l 1 4 ) O j 260.15-1 Rev. 46, 03/86 i ., -, - - -, -,,.., -. -,, -. ~. -

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LGS FSAR QUESTION 260.18 Describe those provisions for assuring the OA program for j operations is implemented at least 90 days prior to fuel loading. (SRP 17.2.2, item 2)

RESPONSE

Section 17.2.1.2.1 states in part: The Electric Production Department is responsible for quality assurance in the-operating nuclear plant from the acceptance of each system, from the Architect Engineer (Startup Phase), through the life of the plant. j(' l0 f 5 O 260.18-1 Rev. 46, 03/86 ~

. _ = LGS FSAR OUESTION 260.20 Describe those provisions which assure procedures are established requiring a documented check to verify the dimensional accuracy and completeness of design drawing and specifications. (SRP 17.1, 3EI)

RESPONSE

Sections 17.2A.3.2, 17.2A.3.3, and 17.2A.3.2.1 provide the requested information. \\3h$\\h[ hf i O i I i l l O 260.20-1 Rev. 46, 03/86

LGS FSAR OUESTION 260.22 Describe those provisions which assure guidelines or criteria are established for determining the method of design verification (design review, alternate calculations, or test). (SRP 17.1, 3E3)

RESPONSE

Sections 17.2A.3.3, 17.2A.3.4, and 17.2B.3 provide the requested information. ,pf" g's a t '>. g, iwe.. + ju,) ,- x R \\ i. g$ , \\, (d85 ;" fi % k g 1 .\\ i l l l 260.22-1 Rev. 46, 03/86

LGS FSAR OUESTION 260.26 Describe those provisions which assure that responsible plant personnel are made aware of design changes / modifications which may affect the performance of their duties. (SRP Section 17.2.3, item 2)

RESPONSE

Procedures shall ensure that responsible plant personnel are made aware of design changes / modification which may affect the performance of their duties. Sections 13.2.2.1.3 and 13.2.2.2.1 provide additional information. f ( ,, 3. n 'i 3 y a 4 \\ o,4 + ' I-d) "p '\\ ~ Rh+ fNYGlh tup a)%y% \\ %P kQ l l l i I 260.26-1 Rev. 46, 03/86 ~

LGS FSAR i OUESTION 260.28 Describe the extent as-built documents are controlled under the QA program. (SRP 17.1, 6Ald)

RESPONSE

l l As-built 0-listed documents are controlled by the OA program. Established procedures prescribe a specific method to be followed upon completion of any plant modification. The procedures l include notification of completion by field personnel, mark-up on drawings of any changes from the original design, and approval of as-built drawings equivalent to that for the original design. Sections 17.2B.3.6L and 17.2A.3.1 provide additional information. l

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n i . :.) ' e, gw % i I t I t !O l 260.28-1 Rev. 46, 03/86 l

I LGS FSAR QUESTION 260.29 l Describe those provisions which assure that procedures are established for the review, approval, and issuance of documents and changes thereto and that the documents are reviewed for technical adequacy and inclusion of appropriate quality requirements prior to implementation. The OA organization, or an individual other than the person who generated the document but qualified in quality assurance, reviews and concurs with quality affecting documents with regards to OA-related aspects. (SRP 17.1, 6A2)

RESPONSE

l Sections 17.2B.6.1, 17.2A.6.3, 17.2A.5, and 17.2A.6 provide the requested information. <fA r 4 sg (My ; "- .3. m p c,t'ft\\; (.. N-j) "}; q( y gm sg s b9 il g Q y l l 260.29-1 Rev. 46, 03/86 1 -~- -..-v.,-, - -. -

LGS FSAR OUESTION 260.30 Describe those provisions which assure that procedures are established to provide for the preparation of as-built drawings and related documentation in a timely manner to accurately reflect the actual plant design. (SRP 17.1, 6C1)

RESPONSE

Sections 17.2A.3.1, 17.2B.3.6L, and 17.2B.3.7 provide the requested information. ,) jf y "'- l f x:%(,,c'c: s , s f < <. 3 's ,f ,... ) f,f,,\\ ) 5 %'t ',p i l I i i 260.30-1 Rev. 46, 03/86 \\ -.~-. - -... - - -, - - -. - -. _. -. -. - - - - - -

LGS FSAR QUESTION 260.31 Describe in more detail the responsibilities of the QA l organization for the control of purchased material, equipment, and services, including interfaces between design, procurement, and QA organizations. (SRP 17.1, 7A1) i

RESPONSE

E&R OA personnel shall review procurement documentation for major modiffcations. EP QA personnel shall review procurement documer.tation for minor modifications and operations procurement. The responsible Engineer shall determine source inspection requirements. Sections 17.2B.4.6, 17.2B.3.5, 17.2B.4.2, 17.2A.4.4, and 17.2A.18.1 provide additional information. ] c y> >. J;.7 y, '7, g g* . a b. S '}.?, y i l ? i i I l l .!O i 260.31-1 Rev. 46, 03/86 i I

LGS FSAR i OUESTION 260.32 i Describe the role of the QA organization relative to the verification of suppliers' activities during fabrication, inspection, testing, and shipment of materials, equipment, and components. (SRP 17.1, 7A2)

RESPONSE

.i Sections 17.2A.7.1 and 17.2B.7.3 provide the requested information. The role of the Engineering and Research Department, Quality l Assurance Division, relative to the verification of suppliers' activities during fabrication, inspection, testing, and shipment of materials, equipment, and components will be evaluated, determined, and implemented on a per case basis for comples;Y 6 'S h l j engineered items with EER QA Division involvement.

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LGS FSAR QUESTION 260.33 Describe those provisions which assure that the results of the selection of suppliers is documented and filed. (SRP 17.1, 7A3) I 1

RESPONSE

Section 17.2B.7.2 provides the requested information. l 1 ..) ,/ r .,. / , \\.. .. Nf',h og,; s

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LGS FSAR OUESTION 260.37 Describe those provisions which assure that criteria are i established for determining those processes that are controlled l as special processes. (SRP 17.1, 9A1)

RESPONSE

Sections 13.5, 17.2A.9.1, and 17.2B.9.1.1 provide the requested i information. '. )j / _f. ~

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O 260.37-1 Rev. 46, 03/86

LGS FSAR QUESTION 260.38 Describe the responsibilities of the QA/QC organization for the qualification of special processes, equipment and personnel and in assurir.g that these qualifications have been satisfactorily performed. (SRP 17.1, 9A2 & 9B1)

RESPONSE

l es 4 j9) l Section 17.2A.9 provides the requested information. ,'\\ ') ^ . )os' ( .. h*':\\ ep,,4 fx {j)b ?gj9h2j/* o O 260.38-1 Rev. 46, 03/86

LGS FSAR QUESTION 260.40 l Identify the organization responsible for inspection and provide assurance that individuals performing inspections are other than those who performed or directly supervised the activity being inspected and do not report directly to the immediate supervisors who are responsible for the activity being inspected. If theA individuals performing inspections are not part of the QA/QCe4 organization, the inspection procedures, personnel qualificaE criteria,andindependencefromunduepressuresuch.as;costJand schedule should be reviewed and found acceptable bylthe3Qh organization prior to the initiation of the activitf.)$(SRP 17.1, 10B1) .y. QU [h Q .c

RESPONSE

1 (4 Q'O Sections 17.2.1.2.3.4, 17.2.1.2.5.3.6, 17.2.1.3.4.3, 17.2.1.3.5.3, 17.2A.10.1, 17.2A.10.9, 17.2B.10.1, and 17.2B.10.3 provide the requested information. i !O I i i O 260.40-1 Rev. 46, 03/86

LGS FSAR i OUESTION 260.42 l Describe those provisions which ensure that inspection results are documented, evaluated and their acceptability determined by a responsible individual or group. (SRP 17.1, 10C3) i

RESPONSE

os 17.28.10.2 provide the requested information. .andh. T)' Sections 17.2A.10.1, 17.2A.10.3, 17.2A.10.8, 17.2A.10.9, sj i 4:y k$*h:"' (p.4.%) $[ l l O i 1 260.42-1 Rev.

3/86 i

LGS FSAR QUESTION 260.43 Describe the provisions which assure that when inspections associated with normal operations of the plant (such as routine maintenance, surveillance, and tests) are performed by individuals other than those who performed or directly supervised the work, but are within the same group, the following controls are mets (SRP Section 17.2.10, item 2) v. ^ . s 4 Q;//r a. The quality of the work can be demonstratedsthrough a functional test when the activity involves:bresching a g' fre(gg, QiQ pressure retaining item. m eksid' RU b. The qualification criteria' form nsp&ction? rs nnel are reviewed and found acceptab1 %gP#the Q ization prior to initiating the insp(ettion.

RESPONSE

.q., Sections 17.2A.10.1, 17.2A.11.1, 17.2A.11.1.1, and 17.2A.2.10 provide the requested information. In addition, Limerick is committed to Regulatory Guide 1.58, l Revision 1, 1980, which endorses ANSI N45.2.6-1978. This standard provides the qualification criteria for inspection personnel. The Limerick OA Plan, Volume III (Operations Phase) describes the measures, Administrative Procedures, that shall implement these criteria and as stated above, the Administrative Procedures are all reviewed and approved by the Superintendent, OA Division. l l t O 260.43-1 Rev. 46, 03/86

LGS FSAR QUESTION 260.44 Describe those provisions which assure that program procedures provide criteria for determining the accuracy requirements of test equipment, and the criteria for determining when a test is required, providing mandatory inspection holding points as required. (SRP 17.1, 11A1 & 11 Bid)

RESPONSE

g, r %,4 \\h 4 Sections 17.2A.11.2, 17.2A.12.1, 17.2A.12.2, 17. 2A.12. 3, - (?'; \\ Y M 17.2A.10.3, 17.2B.11.1, 17.2B.11.2, 17.2B.11.3, and 17.2B.11}4'fV provide the requested information. .fi6,fW 5 J: <

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x._gy i r r i i ) 260.44-1 Rev. 46, 03/86

LGS FSAR () OUESTION 260.45 Describe the OA and other organizations responsible for establishing, implementing and assuring effectiveness of the calibration program. (SRP 17.1, 12.2) Ah

RESPONSE

C? . hh , L F l;y Sections 17.2A.12.2 and 17.2B.12.1 provide the requested;- J l information. s In addition, organizations responsible for(est'abli b 'g) ( implementing and assuring effectiveness #.ofithei, calibre ion program are delineated in the Limerick?Q(}P1pn', Velue III and Limerick Generating Station Staff; Testi@y esponsig res IV (Operations Phase). The organizatio g p and Laboratories Division; Electric Production OA Division; and Engineering and Research Quality Assurance Division. O l I l i i O 260.45-1 Rev. 46, 03/86

[ LGS FSAR OUESTION 260.49 Describe those provisions which assure that procedures are established to control altering the sequence of required tests, inspections, and other operations important to safety. Such actions should be subject to the same controls as the original review and approval. (SRP 17.1, 14.3)

RESPONSE

(% <f Sections 17.2A.14.1 and 17.2B.14.3 provide the requested 4 \\;t ) <~' 'w, -j ks information. ..) - (:-, (Q ( ( 4 { i i i i i l 260.49-1 Rev. 46, 03/86 i i -}}

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