ML20214C353
| ML20214C353 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 11/14/1986 |
| From: | Woolever E DUQUESNE LIGHT CO. |
| To: | Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| 2NRC-6-118, TAC-62931, NUDOCS 8611210074 | |
| Download: ML20214C353 (12) | |
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M 2NRC-6-118 Beaver Valley No. 2 Unit Project Organization S.E.G. Building Telecopy 2
3-520 Ext.160 P.O. Box 328 Nov. 14, 1986 Shippingport, PA 15077 United States Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406 ATTENTION:
Mr. Richard W. Starotecki Division of Project and Resident Programs
SUBJECT:
Beaver Valley Power Station - Unit No. 2 Docket No. 50-412 100FR50.55(f) Evaluation of a PSAR 0A Program Organizational Change Gentlemen:
The purpose of this letter is to provide the attached 10CFR50.55(f) evaluation and associated side bar pages of an organizational change to the Quality Assurance Program description (Section 17, BVPS-2 PSAR).
As described in the evaluation, the change will aid the Duquesne Light Nuclear Group as the Beaver Valley Unit No. 2 project evolves from construction to startup and will provide the organizational freedom necessary for the QA Program to be implemented in accordance with the requirements of 10CFR50 Appen-dix B.
This change does not reduce the commitments in the program description previously accepted by the NRC.
DUQUESNE LIGHT COMPANY 8611210074 e61114 By M
PDR ADOCK 0500 2
E. VJ.'Wo61ever A
Vice President Special Nuclear Projects JJS/ijr NR/PSAR/ CHANGES y
Attachment
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cc:
Mr. P. Tam, Project Manager (w/a) g Mr. L. Prividy, NRC Resident Inspector (w/a) f NRC Document Control Desk (w/a) l; I
United States Nuclear Regulatory Commission Mr. Richard W. Starostecki 10CFR50.55(f) Evaluation of PSAR OA Program Organizational Change Page 2 COMMONWEALTH OF PENNSYLVANIA )
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SS:
COUNTY OF BEAVER
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On this / M day o Ai///6
/
, before me, a Notary Public in and for said Commonwealth and County, personally appeared E. J. Woolever, who being duly sworn, deposed and said that (1) he is Vice President of Duquesne Light, (2) he is duly authorized to execute and file the i
foregoing Submittal on behalf of said Company, and (3) the statements set forth in the Submittal are true and correct to the best of his knowledge.
1/A.)
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Notary Public SHtitA M. FATTORE Il0TAtf PU9tfC SMIPPl!;8 PORT BORD, Sf4 tit CotifnY MY C0991$$10N DPIRS OCT. 23,1989 bber. Pennsylvanis AssociaJoe of Kotwfas 4
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DUQUESNE LIGHT COMPANY Nuclear Group Quality Assurance Unit Evaluation - 10CFR50.55 (f)
Subj ect:
BVPS-2 PSAR, Section 17 1.1 Pages Affected by the Change 17.1-6, 8, 9, 11, 14, 34 Figures 17-1A, 17.1-1A, 17.1-3A 1.2 Identification of the Change Figure 17.1-1A has been revised to reflect current titles and reporting assignments pertaining to the Unit 2 functional organization.
1.3 Reason for the Change The organization changes will aid the Duquesne Light Nuclear Group as the Beaver Valley No.
2 Unit Project evolves from construction to startup.
1.4 Basis for concluding that the revised program incorporating this change continues to satisfy the criteria of 10CFR50, Appendix B and the Safety Analysis Report Quality Assurance Program description commitments previously accepted by the NRC:
The administrative changes provide the organizational freedom necessary for the QA Program to be implemented in accordance with the requirements of 10CFR50, Appendix B.
Prepared By:
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Date: I l tA.
Reviewed By:
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?i Date:
4(-t 2 dG Approved By: '
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BUPS-2 PSAR It is intended that this program shall apply to any activity at or pertaining to the Beaver Valley Power Station. This shall include Duquesne Light
- Company, their designated architect-engineer, and all vendors, contractors, and subcontractors at their general offices, shops, testing facilities, and the nuclear power plant site.
The program vill apply through the
- design, procurement, construction, testing, and operation phases of the Beaver Valley Power Station.
The quality assurance program implementation is the responsibility of the Quality Assurance Manager who reports directly to theSeniorl Vice President, Nuclear Group.
All organizations with direct contractual obligations to Duquesne Light Company and internal Duquesne Light Company groups and units are transmitted policies and programs that commit them to the provisions of the Duquesne Light Company Quality Assurance Program.
The Quality Assurance Manager is responsible for the preparation and controlled distribution of a Quality Assurance Program Manual encompassing the detailed requirements for the implementation of the program.
The Duquesne Light Company organization is described in Section 17.2.1A.
Figure 17.1-1A shows the Duquesne Light Company organization for quality assurance. Figure 17.1-2A shows the Duquesne Light Company Quality Assurance Unit.
Figure 17.1-3A shows the Duquesne Light Company Nuclear Group.
Portions of the Quality Assurance program have been delegated to Stone & Vebster Engineering Corporation (S&V) and to Vestinghouse Electric Corporation.
The Quality Assurance organization chart (Figure 17-1A) shows the relationship for implementing the Quality Assurance program.
The Stone & Webster Quality Assurance program is described in Section 17.1B.
Figure 17.1.1B-1 shows the Stone & Vebster organization for Quality Assurance.
The Vestinghouse Quality Assurance plan is described in Section 17.1C.
1 17.1-6
BVPS-2 PSAR This document summarizes the activities pertinent to Quality Assurance of the Beaver Valley Power Station (BVPS). As BVPS-2 nears completion, Duquesne Light may assume certain responsibilities that vere previously delegated to others.
More details are included in the pertinent Duquesne Light Company, Stone & Vebster (S&W), and Vestinghouse manuals.
17.2.1.1A Organization The Duquesne Light Company Quality Assurance organization consists of a Quality Assurance Unit directed by the Quality Assurance Manager.
Sufficient personnel are available to implement the Quality Assurance program. All items pertinent to Quality Assurance are under his supervision.
The Quality Assurance Manager reports directly to the Duquesne Light Company Senior Vice President, Nuclear Group.
The effort of the l Quality Assurance Manager is directed solely to Quality Assurance.
He purposely has no responsibilities for project costs or project schedule considerations.
This eliminates the possibility of such factors influencing his performance in Ouslity Assurance.
The Duquesne Light Company Quality Assurance program provides written
- policies, procedures, and instructions governing the Quality Assurance activity.
These are identified in the Duquesne Light Company Quality Assurance Program Manual.
This manual details specific responsibilities for implementation of the program.
Duquesne Light Company personnel supporting the Quality Assurance effort include the Nuclear Group, Administrative Services Group, and 1
Power Supply Group.
THe Administrative Procedures of organizations delegated responsibilities in the Quality Assurance Program are reviewed by the Quality Assurance Unit for compliance with the requirements of the Quality Assurance Progras.
The Duquesne Light Company Quality Assurance Unit, under the direction of the Quality Assurance Manager, is divided into five major sections (the Quality Assurance Unit Organization is shown in Figure 17.1-2A). These sections,are i
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17.1-8 l
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- -. - -. - -. - -,.. ~
- ---------..~ - - - - --- -
BVPS-2 PSAR 1.
Engineering and Procurement - headed by the Director
- 0. A. Engineering and Procurement.
2.
Operations - headed by the Director QA Operations.
3.
Inservice Inspection headed by the Director Inservice Inspection.
4.
Operations Quality Control - headed by the Director Operations Quality Control.
5.
Site Quality Control - headed by the Director, Quality Control.
The Quality Assurance Manager reports to the Senior Vice-President, Nuclear Group.
He is responsible for the development and implementation of a Quality Assurance Program for the Design, Procurement, Construction, Operation, and modification of Nuclear Power Stations.
The Director Quality Assurance, Engineering / Procurement supervises Audits and Surveillances related to Design, Engineering, Procurement, and Modification; directs Auditing and Surveillance of the Duquesne Light Organization, A/E, NSS, and Vendors during Design, Engineering, Procurement, and Modificaitons; supervises Engineering Assurance Review and verifies Quality Assurance Requirements are addressed in Administrative Documents.
The Director Quality Assurance, Operations supervises Quality Assurance Audits and Surveillances of Operational Activities and Maintenance; supervises Technical Specification Audits; and supervises Surveillance of Plant Activities.
The Director Inservice Inspection develops and implements the Inservice Inspection and Nondestructive Examination Programs; supervises personnel performing NDE Activities in support of the PSI /ISI Programs; and implements and directs Inspection Activities for Technical Specification Inspection Programs.
The Director Operations Quality Control implements the Quality Control Program; directs Surveillance and Inspection Activities; directs Vendor Surveillance Activities; identifies required Quality Control Inspection Tests, and Surveillances; and identifies and evaluates Trends in Non-conformances.
There are two tiers of Quality Assurance Unit personnel below the Director level. Their function is to assist in carrying out the responsibilities assigned to their respective director as described above.
17.1-9
BVPS-2 PSAR The Vendor Surveillance Supervisor is responsible to the Director Operations Quality Control for coordinating and conducting Duquesne Light Company inspections at the vendor plant.s i
Site contractors shall have either a Quality Control Program or a Quality Inspection Program that meets the requirements of the Duquesne Light Company Quality Assurance Program. These programs are reviewed by the Quality Assurance Unit to assure compliance to the Duquesne Light Company Program including the requirement of organizational independence of Quality Control and/or Inspection personnel.
The Duquesne Light Company Project Management Committee is chaired by the Duquesne Light Company Senior Vice President,NuclearGroup.l Members of the committee include appropriate unit heads from the Nuclear Group and the Administrative Services Group. The Quality Assurance Manager is a member of the committee and by charter is further designated as the secretary. Through this mechanism Duquesne Light Company management is cognizant of all Quality Assurance matters. The committee is also chartered to resolve impasses which may occur in quality matters. Meetings are conducted quarterly or at the specific request of any member, as necessary. Minutes of the meetings are recorded and distributed to all members.
The Duquesne Light Company Engineering Departments will review and/or approve selected general design concepts, calculations, materials adequacy, specifications, bid evaluations, purchase requisitions, drawings, and correspondence in accordance with approved procedures.
All nuclear engineering activities are governed by written procedures or directives. Those procedures that are administrative in nature are reviewed by the QA manager.
Nuclear Group Reporting directly to the Senior Vice President, Nuclear Group are the Vice President of Special Nuclear Projects, the Vice President of Nuclear Operations, the Senior Manager, and the Quality Assurance Manager. The Nuclear Engineering and Construction General Manager, i
the Nuclear Operations General Manager, and the Nuclear Services l
General Manager report to the Senior Manager. All quality-related activities of the Nuclear Group are documented by policies, directives, procedures, instructions, etc.,
of a type appropriate to the activity.
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Design and Construction Phase Nuclear Group Responsibilities:
ll The Senior Vice President, Nuclear Group is responsible for l Engineering, Construction, Support Services, Licensing and Startup i
activities associated with the BVPS-2 Project.
17.1-11 l
BVPS-2 PSAR The Duquesne Light Company Quality Assurance Program is defined in the Duquesne Light Company Quality Assurance Manual.
This manual provides the overall Quality Assurance Policy developed for Duquesne Light Company and is approved by the President and Chief Executive Officer. Additionally, this manual provides the Quality Assurance Procedures which define the programs that have been established for (a) the design and construction phase, and (b) the operations phase (including nuclear fuel).
The Duquesne Light Company Quality Assurance Program endorses the requirements of the Safety Analysis Report that apply to Quality Assurance and is the basis for the development of all other quality-related programs and procedures for the project. Quality Assurance Procedures developed for design / construction and operation (including nuclear fuel) phases and the identification of the criteria of Appendix B to 10CFR50 being implemented are provided in Tables 17.1.1A, 17.1.2A, and 17.1.3A respectively.
The Quality Assurance Sections of the Quality Assurance Unit have developed the Quality Assurance Instruction Manual to define the means and methods by which members of these sections implement the requirements of the SAR and the Duquesne Light Company Quality Assurance Program.
The Director of Quality Control has developed a Site Quality Control Manual to define the means and methods by which the Site Quality control members of the Quality Assurance Unit implement the requirements of the SAR and the Duquesne Light Company Quality Assurance Program.
A Vendor Surveillance Manual has been developed to define the means and methods by which the vendor surveillance section implements the requirements of the SAR and Duquesne Light Company Quality Assurance Program.
Portions of the Quality Assurance Program have been delegated to Stone & Webster and Westinghouse as the Architect-Engineer and Nuclear Steam System Supply respectively.
Their responsibilities have been documented in appropriate manuals and l
procedures and have been subjected to audits by the Duquesne Light l
Company Quality Assurance Unit.
l All activities affecting quality shall be accomplished under controlled conditions utilizing appropriate equipment, suitable environmental conditions, and with assurance that all prerequisites for the given activity have been satisfied.
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l 17.1-14
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BVPS-2 PSAR l
17.2.1.18A Audits The Duquesne Light Company Quality Assurance Program requires that a comprehensive system of planned and periodic audits shall be carried out to verify compliance with all aspects of the quality assurance program and to determine the effectiveness of the program.
The audits shall be performed in accordance with j
vritten procedures or check lists by appropriately trained personnel not having direct responsibilities in the areas being audited.
Audit results shall be documented and reviewed by management having responsibility in the area audited.
Follow-up action including reaudit of deficient areas shall be taken where indicated.
Audits should include, but not be limited to, an objective evaluation of QA program contents, such as practices, procedures and instructions, and their implementation as well as an evaluation of work areas, activities, processes and items and i
should include a review of documents and records pertaining to the subject work including implementation of corrective action.
Stone & Vebster, as agent for Duquesne Light Company, has been delegated the responsibility for auditing to the provisions of the Stone & Webster Quality Assurance Program during the engineering and construction phase as described in Section 17.1B.
Similarly, Vestinghouse is delegated the responsibility for auditing to the provisions of the Westinghouse Quality Assurance Program for the i
NSSS as described in Section 17.1C.
In addition to these audits, the Duquesne Light Company Quality Assurance Unit will perform its own periodic audits to assess the adequacy of the Stone &
4 Webster and Vestinghouse Programs, as well as certain selected contractors or subcontractors of both Companies.
The Duquesne Light Quality Assurance Manager is also responsible for the auditing of all applicable company Units or departments, as well as company contractors or subcontractors participating in the Duquesne Light Company Quality Assurance Program.
These audits will be performed at a frequency commensurate with their importance as well as the quality record of the group involved.
Copies of all audit findings and recommendations are transmitted to the appropriate management level of the organization involved i
as well as to the Duquesne Light Company Senior Vice President, l
Nuclear Group.
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17.1-34 i
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DUQUESNE LIGHT COMPANY Senior Vice President (REF 17.l-IA)
Nuclear Group DUQUESNE LIGHT COMPANY gpgp 7,g
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QUALITY ASSURANCE MANAGER f
l STONE G WESSTER STONE GWEBSTER WESTINGHOUSE ENetNEERING CORPORATION ENGINEERING CORPORATION ELECTRIC COMPANY j
CHIEF EIGGHIEER.
MANAGER.00ALITY ASSURANCE PROJECT MANAGER ENGINEER 1006 ASSURA00CE (REF FIG 17. I. Is - 3)
(REF FIG.17.1.18. )
(REF IF.
IC)
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( RESAR 3) 1 l
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FIG. 17 - l A l
COe8MUNICATION = - - - -- -- -
RESPONSIBILITY =
PROJECT ORGANIZATION BEAVER VALLEY POWER STATION - UNIT 2 PRELIMINARY SAFETY ANALYSIS REPORT
President and UNII"*" "I Chief Executive Officer the Board I
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I Nuclear Group g
Senior Vice President g
I L__3 Nuclear h er SuPP F Operations I
Administrative Services Group Vice President ce rest ent i
Vice President 1
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Vice President of Senior Manager
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Sp,cg,y y,cg,,,
1 Projecta 1
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l Nw Iea r EngineerinR Nuclear Services BVPS-2 General Services Materf.ils
.uul 4.nestruction Nuclear Operations Ceneral Manager Quality Assurance Project General Manager Management General Manager Manager L.ocial Mana C Manages Icgend Figure 17.l-IA Duquesne Light Company Lines of Responsibility Organization for Quality Assurance Beaver Valley Power Stat lon - thalt 2
i.ines of Commsunication Preliminary Safety Analysis Report
Senior Nuclear Group i
Vice President I
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l Special Nuclear Project s Vice President 1
I Nuclear Technical j
Assistent i
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1 Engineering &
Start-up &
Quality Construction Operatione Assurance i
Nanager Manager Manager I
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l Figure 17.1 - 3A Duquesne Light Company i
l BVPS-2 Project l
Beaver Valley Power Station - Unit 2 Preliminary Safety Analysis Report 1
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