ML20235H761
| ML20235H761 | |
| Person / Time | |
|---|---|
| Site: | Dresden, Byron, Braidwood, Quad Cities, Zion, LaSalle, 05000000 |
| Issue date: | 06/30/1987 |
| From: | COMMONWEALTH EDISON CO. |
| To: | |
| Shared Package | |
| ML20235H590 | List: |
| References | |
| 9518M, CE-1-A, NUDOCS 8707150251 | |
| Download: ML20235H761 (115) | |
Text
. _ _ - _ - _
s.i:n CE-1-A' 1-.
s Topical. Report January 1976
., j Rev. 45 - 6/30/67 i
l q..
!J C' COMMONWEALTH E-D I S O N COMPANY QUALITY ASSURANCE PROGRAM FOR NUCLEAR GENERATING STATIONS
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COMMONWEALTH EDISON COMPANY Post Office Box 767 l
Chicago, Illinois 60690 p[
R ADO O
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LISTING COVERING REVISION OF TOPICAL REPORT CE-1 Below is a listing of Revision 45 changes to the Commonwealth Edison Company Quality Assurance Program Topical Report CE-1-A dated 6/30/87:
Rev. Contents Pages 1-3, Appendix A Index, Page Nos.
1-1, 1-4-1-10, 1-12, 1-13, 1-15, 1-17, 1-18, 1-19, 1-21-1-27, 1-30, 1-32-1-39, 1-41-1-44, 2-1, 2-6, 2-7, 3-1, 3-2, 3-3, 3-4, 4-2, 4-3, 5-2, 6-2, 6-3, 7-1, 7-2, 9-3, 11-3, 15-2, 15-3, 16-2, 18-1, 18-2 and 18-3.
Approved: ///
d"fd-87 Msn'ager of Quality Assurance 1
6/30/87 9518M i
I 1
________________w
CONTENTS
~
TITLE PAGE REV.
DATE t
INTRODUCTION 1-1 45 06/30/87
- 1. ORGANIZATION A. Basic Organization Responsibilities 1-1 45 06/30/87 1-2 26 12/10/83 B. Organizational Responsibilities for Major Activities 1-3 21 06/06/82 1-4 45 06/30/87 1-5 45 06/30/87 1-6 45 06/30/87 1-7 45 06/30/87 1-8 45 06/30/87 1-9 45 06/30/87 1-10 45 06/30/87 1-11 28 03/16/84 1-12 45 06/30/87 1-13 45 06/30/87 1-14 40 02/28/86 1-15 45 06/30/87 1-16 28 03/16/84 1-17 45 06/30/87 1-18 45 06/30/87 1-19 44 02/25/87 1-20 28 03/16/84 1-21 45 06/30/87 1-22 45 06/30/87 1-23 45 06/30/87 1-24 45 06/30/87 l-25 45 06/30/87 1-26 45 06/30/87 1-27 45 06/30/87 1-28 34 04/10/85 1-29 34 04/10/85 1-30 45 06/30/87 1-31 34 04/10/85 1-32 45 06/30/87 1-33 45 06/30/87 1-34 45 06/30/87 1-35 45 06/30/87 1-36 45 06/30/87 FIGURES 1-0
. Organization Chart Related To Q. A.
1-37 45 06/30/87 1-1 Organization Chart - Quality Assurance 1-38 45 06/30/87 1-2 Station Construction Department 1-39 45 06/30/87 1-2.1 CDCo Nuclear Generating Station Site 1-40 12/29/80 Organization Interface Relationships 1-3 Station Nuclear Engineering Department 1-41 45 06/30/87 1-4 Projects Department 1-42 45 06/30/87 1-5 Operational Analysis Department 1-43 45 06/30/87 and Materials Analysis Department 1-6 Production 1-44 45 06/30/87 1-7 Station Production Department Organization 1-45 42 11/21/86 Page 1 of 3 Date:
6/30/87 Rev. 45
I
' CONTENTS
+
TITLE-PAGE REV.
DATE
- 2. QUALITY ASSURANCE PROGRAM 2-1
~45 06/30/87 2-2 42.
11/21/86 2-3 39 11/20/85 2 19 08/07/81 2-5 43 12/22/86 2-6 45 06/30/87-2-7 45 06/30/87 2-8 29 04/20/84
- 3. DESIGN CONTROL 3-1 45 06/30/87 3-2 45 06/30/87 3-3 45 06/30/87.
3-4 45 06/30/87
- 4. PROCUREMENT DOCUMENT CONTROL 4-1 33 03/13/85 4-2 45
.06/30/87 4-3 45 06/30/87 4-4 42 11/21/86 4-5 16 03/16/81
- 5. INSTRUCTIONS, PROCEDURES AND DRAWINGS 5-1 39 11/20/85 5-2 45 06/30/87 5-3 36 06/19/85
- 6. DOCUMENT CONTROL 6-1 32
-10/05/84 6-2 45 06/30/87 6-3 45 06/30/87
- 7. CONTROL OF PURCHASED MATERIAL, EQUIPMENT AND SERVICES 7-1 45 06/30/87 7-2 45 06/30/87 I
I 7-3 32 10/05/84 7-4 18 07/12/81 7-5 42 11/21/86 7-6 18 07/12/81
- 8. IDENTIFICATION AND CONTROL OF MATERIALS, PARTS AND COMPONENTS 8-1 42 11/21/86 8-2 10 09/28/79
- 9. CONTROL OF SPECIAL PROCESSES 9-1 15 01/02/81 9-2 32 10/05/85 9-3 45 06/30/87
- 10. INSPDCTION 10-1 42 11/21/86 10-2 42 11/21/86 10-3 33 03/13/85
- 11. TEST CONTROL 11-1 15 01/02/81 11-2 41 08/12/86 11-3 45 06/30/87 11-4 39 11/20/85 Page 2 of 3 Date: 6/30/87 Rev. 45 j
COMTENTS l
TITLE PAGE REV.
DATE l
- 12. CONTROL OF MEASURING AND TEST EQUIPMENT 12-1 42 11/21/86 12-2 42 11/21/86 12-3 39 11/20/85
- 13. HANDLING, STORAGE AND SHIPPING 13-1 26 12/10/83 13-2 26 12/10/83 13-3 11 12/21/79
- 14. INSPECTION, TEST AND OPERATING STATUS 14-1 42 11/21/86 14-2 26 06/19/85
- 15. NONCONFORMING MATERIALS, PARTS OR COMPONENTS OPERATIONS 15-1 26 12/10/83 15-2 45 06/30/87 15-3 45 11/20/85
- 16. CORRECTIVE ACTION 16-1 29 04/20/84 16-2 45 06/30/87 16-3 15 01/02/81
- 17. QUALITY ASSURANCE RECORDS 17-1 26 12/10/83 17-2 39 11/20/85
- 18. AUDITS 18-1 45 06/30/87 18-2 45 06/30/87 18-3 45 06/30/87 APPENDIX A A-1 Quality Assurance Program Mantal Index A-1 Quality Assurance Procedures Manusl A-2 Index (Engineering and Construction)
Quality Assurance Procedures Manual A-3 Index (Operations)
Page 3 of 3 Date: 6/30/87 Rev. 45 Approved: /B9Mr 4 30- 7 9522M Mandg'er of Quality Assurance
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EXPLANATION OF CHANGES FOR TOPICAL REPORT - REV. 45 COMMONWEALTH EDISON COMPANY PROGRAM TOPICAL REPORT CE-1-A i
I PAGE NO.
EXPLANATION Appendix A Updated to show current listing of Quality Procedures.
1-1, 1-4-1-10, 1-12, Revised to change the job titles and 1-13, 1-15, 1-17, 1-18, organization titles, as well as the l
1-19, 1-21-1-27, 1-30, resultant job responsibilities, to 1-32-1-39, 1-41-1-44 agree with the reorganization of the Nuclear Division, which provides for nuclear stations BWR and PHR departments.
The changes resulting from the nuclear division reorganization basically involve establishment of a BWR and a PHR Nuclear Stations Department, each headed by a Vice President reporting to a new job position of Senior Vice President (Nuclear Operations) establishing Engineering in each of the new nuclear station BWR and PHR Departments and reorienting -the support services for these two new departments. Also, the revision includes a change to reflect the elimination of the Operations Quality Assurance Manager and reorganization to one Executive Vice President.
2-1 Revised to insert completion dates for LaSalle and Zion Stations, originally omitted.
2-6 Reissued due to a typographical error.
No change to text.
2-7 Revised to reflect title changes as a result of the Nuclear Division reorganization.
f 3-1-3-4, 4-2, 4-3, Revised to reflect title changes as a I
5-2, 6-2, 6-3, 7-1 result of the Nuclear Division 7-2, 9-3, 11-3, 15-2, reorganization and to reflect changes 15-3, 16-2, 18-3 as a result of the LaSalle ASME Survey.
18-1, 18-2 Revised to change " Director of Quality Assurance (Operating)" to " Director of Quality Assurance (Operations)".
0012M l
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i APPENDI X A
QUALITY ASSURANCE PROGRAM MANUAL INDEX 0
Preface 0
Introduction 0
ASME Code Interface 0 Definitions Quality Requirements 1.0 Organization 2.0 Quality Assurance Program 3.0 Design Control 4.0 Procurement Document Control 5.0 Instructions, Procedures and Drawings 6.0 Document Control 7.0 Control of Purchased Material, Equipment and Services 8.9 Identification and Control of Materials, Parts and Components 9.0 Control of Special Processes
- 10. 0 Inspection 11.0 Test Control 12.0 Control of Measuring and Test Equipment 13'.0 Handling, Storage and Shipping 14.0 Inspection, Test and Operation Status A-1 Rev. 45 6/30/87
~
' Quality Requirements 15.0 Nonconforming Materials, Parts or Components 16.0 Corrective Action 17.0 Quality Assurance Records 18.0 Audits O
Appendix B, 10CFR50, " Quality Assurance Criteria for Nuclear Power Plants" Station Quality Assurance Manual for Construction, O
Maintenance, Modification, In Service Inspection and Stores Activities l
QUALITY ASSURANCE PROCEDURES MANUAL INDEX (ENGINEERING & CONSTRUCTION)
Quality Procedures 2-1 Procedure for Revision of the Quality Assurance Manual 2-2 Training of Personnel to Meet Quality Assurance Requirements 3-1 Design Control 3-2 Design Change C)ntrol 3-3 Classification af Systems, Components, Parts and Materials 4-1 Request for Bid, Proposal Evaluation and Recommendation 4-2 Evaluation of Contractor's Quality Assurance Program 5-1 Quality Instructions and Procedures 6-1 Distribution of Design Documents 6-2 Procedure for Station Construction Department Design Document Control 7-1 Control of Procured Material and Equipment - Receiving and Inspection 7-2 Off-Site Contractor Inspection A-2 Rev. 45 6/30/87
Quality Procedures 8-1 Identification and Control of Materials, Parts and Components 9-1 Control of Contractor Special Processes
~
10-1 On-Site Contractor Inspection i
10-2 Quality Assurance Mandatory Hold /
11-1 Development, Performance, Documentation and Evaluation Of Construction Tests 11-2 Development, Performance, Documentation and Evaluation of Preoperational and Start-up Tests 12-1 Calibration Control of Commonwealth Edison Test and Measurement Equipment 12-2 Calibration and Control of Station Instrumentation and Control Equipment 12-3 Review of Vendor / Contractor Calibration Activities and Quality Control Records 13-1 Site Handling, Storage, Preservation, Maintenance and Shipping of Material, Equipment and Components 14-1 Inspection and Test 15-1 Repo'rting Quality Nonconformances During Construction and Test 15-2 Reporting Significant Deficiencies that Occur During Construction and Test 16-1 Corrective Action for Reportable Deficiencies & Quality Nonconformances that Occur During Construction and Test 17-1 Quality Assurance Records 18-1 Quality Program Audits 18-2 Surveillance of Contractor Quality Assurance / Control Activities 18-2 ATTACHMENT A Quality Assurance Department Surveillance of Construction Activities QUALITY ASSURANCE PROCEDURES MANUAL INDEX (OPERATIONS)
Quality Procedure 2-52 Quality Assurance Program for Operations - Training 2-53 Quality Assurance Program for Operations - Classification of Structures, Systems and Components A-3 Rev. 45 6/30/87
.___________________________D
guality Procedures
,3-51 Design Control for Operations - Plant Modifications 3-52 Design Control of Operations - Plant Maintenance 3-53 Design Control for Operations - Reactor Analysis 3-54 Design Control for Operations - Digital Computer and Software 4-51 Procurement Document Control for Operations - Processing Purchase Documents 5-51 Instructions, Procedures and Drawings for Operations Procedures Manual 6-51 Document Control for Operations - Transfer of Records 6-52 Document Control for Operations - Distribution and Control of Engineering Documents and Drawing Change Control 7-51 Control of Purchased Materials, Equipment and Services for Operation - Supplier Evaluation 7-52 Control of Purchased Materials, Equipment and Services for Operation - Source Inspection 7-53 Surveillance and Audit of Nuclear Fuel Contractor 8-51 Identification and Control of Materials, Parts and Components for Operations - Identification, Inventory Disbursal and Use 9-51 Control of Special Processes for Operations - Special Processes for Maintenance and Modifications 10-51 Inspection for Operations - Maintenance 10-52 Inspection for Operations - Station Operations 10-53 Inspection for Operations - Technical Support, Surveillance and Inspection 10-54 Inspection for Operations - Receiving Inspection 11-51 Test Control for Operations - Planned Tests 12-51 Control of Measuring and Test Equipment for Operations Portable Test and Measurement Equipment 12-52 Control of Measuring and Test Equipment'for Operations Station Instrumentation 12-53 Standardization and Control of Standard Solutions 12-54 Standardization and Control of Standard Solutions-Nuclear Generating Stations A-4 Rev. 45 6/30/87
I
' Quality Procedures 13-51 Handling, Storage and Shipping for Operations - Control of Equipment, Materials and Nuclear Fuel 13-52 Preparation and Shipment of Radioactive Materials 14-51 Inspection, Test and Operating Status.for Operations 15-51 Nonconforming Materials, Parts and Components for Operations - Spare Parts and Materials 15-52 Nonconforming Materials, Parts or Components for Operations
- Deviations and Incidents 15-53 Nonconforming Materials, Parts and Components for Operations - Inspection and Test 16-51 Corrective Action for Operations - Corrective Action System 17-51 Quality Assurance Records for Operations - Control of Station Records 18-51 Audits for Operations - Quality Assurance Program Audits 18-52 Audit and Surveillance of Maintenance, Spare Parts'and In-Service Inspection Activities
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A-5 Rev. 45 6/30/87 9520M
i QUALITY' ASSURANCE DURING DESIGN, CONSTRUCTION AND OPERATION Introduction This Topical Rep 3rt has been prepared to delineate the requirements governing tte Commonwealth Edison Company Quality Assurance Program for.it!. nuclear generating stations.
Implementa-tion of the Program with Quality Procedures provides the degree of quality assurance commen,surate with the requirements of ASME Section I
III, Division 1. and Divi sion 2 for concrete containment and other applicable codes, Nuclea: Regulatory Commission requirements and
. Federal Regulations governing design, procurement, construction, testing, operation, refueling, maintenance, repair and modification of Commonwealth Edison Company's nuclear power generating facilities.
The scope of this Report covers the total Quality Assurance Program for'the life of the Commonwealth Edison Company generating plants commencing with the construction of the LaSalle County Station and for the operation periods of the Dresden, Quad Cities and Zion plants and is: described in the ensuing 18 sections of this Report.
1.
Organization A.
Basic Organization Responsibilities Commonwealth Edison Company is ultimately responsible for the assurance of quality in all phases of the design, procurement, construction, modification, testing and operation of the Station.
Edison' executes this responsibility in accordance with the program set forth in the Company Quality Assurance Manual and described herein and assigns areas of ultimate responsibility to specific Edison organizations and individuals.
Inherent in the delegation of
- 45 responsibilities is'the assignment of corresponding authority required to execute the responsibilities.
Edison has delegated the responsibility for certain phases of the work to the Architect.
Engineer and the NSSS Supplier, both of whom act as Edison's agents in the assigned areas.
Edison maintains overall control of the efforts of these organizations by various mechanisms such as design j
evaluation and audits.
Edison has prime responsibility for control-ling the quality of on-site work by field contractors.
Also, Edison retains overall responsibility for procurement, design, construction, modifications, and operation of the plant including certification and stamping in accordance with the ASME Code.
1-1 Rev. 45 6/30/87 Commonwealth Edison
The Commonwealth Edison Company Quality Assurance Program for Nuclear Generating Stations covers the organization arrangement whereby the Quality Assurance Department is a separate and independent organization.
The Project Site Construction Superintendent or Construction Superintendent supported by supervisors and/or Field Engineers is responsible for administration of the contracts and verification that construction activities carried out by site contractors conform to procurement document requirements which include performance and quality related functions.
Also, the Construction site group has responsibility for reviewing site contractor quality control procedures, preparing checklists for witnessing inspection notification points at vendor plants, inspection and designation of status of incoming material at the
' site, reviewing inspection procedures and monitoring quality control activities of contractors at the site.
The Quality Assurance site group is responsible for assuring that the quality requirements are fulfilled and for final approval of:
(1) quality assurance procedures of site contractors; (2) the program, including checklists and reports, for witness inspection and audits at contractor plants; (3) site receipt inspection of materials performed by others; and (4) for audit of contractor inspection activities at the site.
Independent Inspection Agency inspection and testing
- 26 activities parformed directly for Commonwealth Edison are under the direction and responsibility of the Site Quality Assurance Superintendent and such Agency shall be staffed with qualified personnel acceptable to Quality Assurance.
Such Agency has responsibility to identify unacceptable or nonconforming work occurring on-site and, when assigned, at off-site supplier's plants.
An Independent Inspection Agency is assigned responsibilities for inspection and testing, to determine and report whether the item conforms to design, test and specification requirements and to reject unsatisfactory materials, equipment and other items.
Such rejection by an Independent Inspection Agency will be the basis for action by the Commonwealth Edison site organizations to carry out necessary steps to assure repair, rework or processing of a nonconformance report in accordance with the Quality Assurance Program.
The Commonwealth Edison Company Quality Assurance Program includes the quality assurance requirements for operating nuclear power stations.
The Program covering operations shall comply with the 18 Criteria of the " Quality Assurance Criteria for Nuclear Power Plants" of Appendix B to 10CFR50 for maintenance, modification and refueling activities and with Criteria 1, 2,
5, 6,
10, 11, 12, 14, 15, 16, 17 and 18 for operating activities.
As supplementary Criteria to the 18 Criteria described above for Appendix B to 10CFR50, the Program also complies with Regulatory Guide 1.33 " Quality Assurance Program Requirements (Operations)" as an acceptable method of complying with l
the Commission's regulations with regard to overall quality assurance l
program requirements.
The Program shall apply to the quality assur-ance activities affecting the safety-related structures, systems and 1-2 Rev. 26 12/10/83
-A
components.
The Program is applicable to the maintenance, modifica-tion, operating and refueling quality assurance activitie s from the time the Operating License is issued to the end of the operating life of the items.
Repairs are performed as maintenance activitbe s and alterations as modifications.
The Program covering operations, including quality control, are planned and implemented in accordance with procedures necessary to provide Commonwealth Edison Company adequate confidence that a safety-related structure, system or component performs satisfactorily in service.
B. Organizational Responsibilities s for Major Activitie s De sign Control of design quality is essentially a four-stage p roces s.
Designs originated by either the NSSS Supplier or Architect Engineer are subjected to internal revis w by the designer and an independent internal party (or parties).
The NSSS Supplier and Architect Engineer designs are evaluated by each other as well as by personnel from one or more Edison departments.
These steps consti-tute the primary design evaluation for all safety-related and ASME Section III items in the Station. Appropriate document distribution and control has been established to permit an effective effort in this area.
Comments on designs resulting from these evaluations are l
presented in letter form, by telephone (with written follow-up) or in meetings with published minutes.
Edison has final authority with respect to decision making on designs.
Procurement Procurement control and follow-up for NSSS components is established and maintained by the NSSS Supplier.
Edison and the Architect Engineer evaluate the NSSS Supp1b r procurement specifi-cations, and Edison audits and inspects the NSSS Supplier control measures.
Procurement of and follow-up on non-NSSS components and l
services are directly controlled by Edison, based on the Architect Engineer specifications which have been evaluated by Edison.
The t
Architect Engineer is used to assist in this effort, as Edison's agent, as requested by Edison.
Construction Edison exercises managerial' y assurance is an Edison responsibility.
Construction qualit control of all site construction activi-j of on-site contractor'y Assurance Group maintains close surveillance ties.
The!oite Qualit s and other associated construction quality assurance activitie s.
The NSSS Supplia r furnishes technical and l
Quality Control assistance for on-site activities relating to the NSSS.
On-site contractors' quality assurance programs are indepen-21 dently evaluated by Edison Quality Assurance.
f 1-3 Rev. 21 6/6/82 Commonwealth Edison i__.
Pre-service Testing Pre-service testing, consisting of preoperational and start-up testing, is controlled by Edison.
The Architect Engineer and the NSSS Supplier furnish rough draft test procedures to Edison.
Based on these, a final draft is written by Edison.
This final draft is subjected to internal Edison evaluation and evaluation by the Archi-tect Engineer or the NSSS Supplier as appropriate.
The tests are managed and performed by Edison with technical assistance from the NSSS Supplier as appropriate.
The evaluation of the test results is performed by Edison and confirmed by independent internal Edison evaluations.
Further independent evaluations by the Architect Engineer or the NSSS Supplier are performed as required by Edison.
Operations Commonwealth's managerial and administrative control of the Quality Assurance Program for operating nuclear stations, as illus-trated in Figures 1-0, 1-1, and 1-6 includes review and approval of procedures by the personnel described in this document.
Quality Procedures and revisions thereto for the Company Manual are concurred with by the principally involved departments.
The Director of Quality Assurance (Operations) reporting to the
- 45 Manager Quality Assurance, verifies that the Quality Procedures for Operating contained in the Company Manual or Station Quality Procedures comply with the policy described in this document.
Similarly, the Director Quality Assurance (Maintenance) verifies that the Quality Procedures for maintenance, modifications, in-service inspection and Stores activities comply.
The Manager
- 45 Quality Assurance approves the Quality Assurance Procedures covering operating, maintenance, modifications, in-service inspection and Stores activities for use in the Station.
Station Procedures and instructions and revisions thereto for the Station Procedures Manual are reviewed and approved as provided in the Technical Specifications.
The Station Quality Assurance Engineer or Inspectors covering operating activities and reporting to the Station Quality Assurance Superintendent provides surveillance of the preparation and revision of the station operating procedures and instructions to assure compliance with the policies contained in the Quality Assurance Program.
The Quality Assurance Engineers or Inspectors for maintenance, reporting to the Station Quality Assurance Superintendent, provide surveillance of the preparation of procedures and instructions for maintenance, modifications, in-service inspections and Stores activities to assure compliance with the policy contained in the Quality Assurance Program.
Temporary changes to procedures which do not change the intent of the original procedures, may be made with the concurrence of qualified individuals as described by Technical Specifications.
l-4 Rev. 45 6/30/87 I
Commonwealth Edison 1
.Such temporary changes are subsequently reviewed, approved and.
l authorized 1in a manner commensurate to that used.for the original
,' procedure.
Managerial and Administrative Controls Lines of authority and responsibility for the Quality Assur-ance Program are documented and updated, as appropriate, in the form of organizational charts, functional descriptions.of departmental responsibilities or descriptions of. key quality assurance positions including those providing technical support or audit-responsibility.
In general, the Quality Assurance Program provides that an activity is verified as being correctly performed, that Quality
-Assurance activities are performed independent of the individual or j
group directly responsible for performing a specific activity, and that Quality Assurance has sufficient authority and organizational freedom to identify quality problems; to initiate, recommend, or provide solutions; and to verify implementation of the solutions.
The responsibilities for implementation of the Quality Assurance Program are assigned to the Executive Vice President,
- 45 Senior Vice President (Engineering), Senior Vice President (Nuclear Stations Operations), Manager of Station Construction, Manager of Projects, General Purchasing Agent, Vice President (Divisions) and Manager Quality Assurance.
The organizations or personnel named herein and reporting to the Chairman and President, Executive'Vice President, Senior Vice President (Engineering), Senior Vice
- 45 President (Nuclear Stations Operations), Manager of Station Construction, Manager of Projects, the General Purchasing Agent and Manager Quality Assurance may assign to other organizations or personnel, the work of establishing and executing any part of the Quality Assurance Program under their cognizance, but the assignir.g organizations or personnel retain responsibility for such
- 45 assignments.
The specific responsibilities for the Quality Assurance Program are described in the following paragraphs.
1.1 General As assigned in the policy statement for the Corporate Quality Assurance Manual by the Chairman and President, the 1-5 Fev. 45 6/30/87 Commonwealth Edison
Manager Quality Assurance has overall responsibility for the Quality Assurance Program covering the design, procurement,
~
construction and operation of the Company's nuclear generating stations.
Other authorities and responsibilities are as delineated i
in the organization section.
l l
The Executive Vice President, Senior Vice President
- 45 (Engineering); Manager Quality Assurance; Senior Vice President l
(Nuclear Stations Operations); Vice Presidents (Nuclear Stations Operations); Vice President (Divisions); Manager of Station Construction; Manager of Projects and General Purchasing Agent are
- 45 responsible for implementation of the Quality Assurance Programs as described herein.
The Manager of Projects directs the design, construction and
- 45 pre-operations operating activities involving the project during the initial design and construction of the nuclear unit or for other specially established projects after the unit has been placed into operation.
The Project Managers are responsible for the Project
- 45 activities involving project construction, testing, and preoperational and start-up operations.
The Projects Engineering Manager, reporting to the Manager of Projects, is responsible for the
- 45 Project activities involving engineering.
The Projects Department Engineering, Construction and Operation groups have line responsibility involving the project during the initial design, construction and preoperational operations of the nuclear unit.
The Project Engineering, Project Construction and Project Operation groups are formulated respectively from the Production Services and
- 45 Station Construction Departments and the Nuclear Stations Division which have functional responsibility and control of the corresponding Projects Department organizations.
The Project Operation group for a respective unit shall revert back to the Nuclear Stations Division
- 45 when an operating license becomes effective or as otherwise provided by the applicable Technical Specifications.
The Project Construction and Project Engineering groups shall revert back, respectively, into Station Construction and Production Servies or the cognizant nuclear
- 45 stations Departments at a point in time which post-dates the issuance of a full power operating license and is mutually agreeable to the cognizant Vice President (Nuclear Stations Operations) and the
- 45 Manager of Projects.
Also, during the projectized phase, the applicable respective Station Construction Department, Production Services and Nuclear Stations Division procedures shall correspondingly apply to the Project Construction, Engineering and Operations activities as established by interface procedures or documents between the Station Construction and Engineering j
Departments and the Nuclear Stations Division, respectively, and the
- 45 I
related Project groups.
The Production Services Manager, reporting to the Assistant
- 45 t
Vice President (Licensing and Plant Support Services), who in turn a
reports to the Senior Vice President (Nuclear Operations), has functional responsibility and control during initial design, construction and startup for the activities involving design, test procedures, and the baseline data for future in-service inspection.
- 45 After the nuclear unit has been issued a full power operating license and has by mutual agreement been turned over from the Manager of
+45 Projects to the cognizant Vice President (Nuclear Stations l-6 Rev. 45 6/30/87 Commonwealth Edison
myeommo.
my m_
m_,
____s for the Commonwealth Edison Company (CECO) nuclear power generating stations.
Production Services is responsible for the overall engineering policies, methods, procedures, design and procurement requirements and has functional responsibility over the activities performed by projects Engineering or the cognizant nuclear stations Engineering Departments or their Architect Engineers.
The Engineerin9
- 45 Department assigned to each grouping of nuclear stations (referenced throughout the Manual as " cognizant nuclear stations Engineering Department") is diretly responsible for the design, testing procedures, and plant modifications for these stations.
The Operational Analysis Manager and the Materials Analysis Manager, both reporting to an Assistant Vice President who in turn reports to the Senior Vice President (Engineering), is responsible,
- 45 respectively, for the testing activities of the Operational Analysis and Materials Analysis Departments and have functional responsibility and control, respectively, of the Operational Analysis and Materials Analysis testing activities during construction and plant operations.
The Manager Quality Assurance directs the quality assurance activities for the design, procurement, construction and operation of the Company's nuclear power facilities and interface activities with the Nuclear Regulatory Commission, Office of Inspection and Enforcement, Region III and the Authorized Inspection Agency.
He, or a designated alternate, is delegated responsibility and authority to stop unsatisfactory work and plant operations as well as further processing or unsatisfactory material during design, engineering and construction of the plant, and during plant modification, maintenance and in-service inspection activities.
Release of stop work orders shall be by the individual who placed the stop work or by a Quality Assurance Department higher authority and shall have the concurrence of the Manager Quality Assurance or his designee.
All Quality Assurance personnel shall have the responsibility
- 45 and authority to cease an in-process operation / installation as necessary, when a violation of the applicable QA Program, procedure, specification or drawing is identified.
Work will be permitted to proceed after implementation of necessary corrective action to bring the in-process installation / operation into conformance has been verified by Quality Assurance.
If conditions, which are adverse to quality and which require prompt action are found by Quality personnel at the site or Station and required corrective measures can not be agreed upon, the Manager Quality Assurance or his designated alternate, will be notified promptly.
The Director of Quality Assurance (Engineering-Construction),
- 45 Director of Quality Assurance (Operations) and the Director Quality Assurance (Maintenance) report to the Manager Quality Assurance.
The Director of Quality Assurance (Engineering-Construction) has responsibility for administering design, procurement and construction
- 45 quality assurance activities.
The Director Quality Assurance (Operations) has responsibility for administering operating quality assurance activities, and the Director of Quality Assurance (Ma inte. nance) has responsibility for quality assurance activities covering maintenance, modification, in-service inspection 1-7 Rev. 45 6/30/87 Commonwealth Edison
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freedom to identify problems and to initiate, recommend or provide j
solutions.
The Quality Assurance organization is independent of the I
groups and individuals directly responsible for performing specific j
activities to which such quality assurance is applicable.
l 1
j l
The qualification requirements for the position of Manager l
Quality Assurance includes having a broad background and working
)
I knowledge of nuclear plant engineering, construction and operating I
activities within Commonwealth Edison Company as well as functional
{
interfaces with working organizations outside the company plus having executive capabilities to achieve goals and objectives in concert with company policies.
Also required is knowledge of Quality Assurance regulations, policies, practices and Standards and experience working in Quality Assurance or related activity in I
reactor design, construction er operation or in a similar high j
technology industry.
Educational requirements include, as a minimum, a baccalaureate degree or equivalent in Engineering or related science.
" Equivalent" is considered to be commensurate with j
the factors described in paragraph 4.1 (items a-j) of ANS-3.1-1981.
j The Manager Quality Assurance shall have (4) years experience in the field of quality assurance, or equivalent number of years of nuclear plant experience in a supervisory position' preferably at an operating nuclear plant or a combination of the two.
At least one (1) year of this four years experience shall include detailed involvement in the administration of and adherence to the Quality Assurance program in a significant technical management 1
responsibility directly involving nuclear power plants, such as engineering, construction, operation, etc.
Job requirements for the positions of Directors of Quality
- 45 Assurance include having a broad background and working knowledge of engineering, construction and operating activities with Commonwealth Edison Company as well as having a knowledge of codes and standards applicable to power plant design, construction and operation and quality assurance principles.
They also shall have superviror and management qualities and capabilities.
Educational requirements shall include a baccalaureate degree or equivalent in engineering or j
a combination of an equivalent technical discipline.
The equivalent
{
technical discipline and work experience requirements for the Directors of Quality Assurance (Maintenance or Operations) as well
- 45 as Quality Assurance Superintendents and Supervisors of Quality j
Assurance may be fulfilled by a combination of education, Quality
{
Assurance and related experience, taking into account past work l
performance, proficiency, totalling about five years.
{
The Executive Vice President for Construction, psoduction and Engineering directs the activities of the nuclear associated
- 45 departments responsible for licensing, construction, testing, plant operations, nuclear and other engineering, security, training and
- 45 environmental affairs.
I In this capacity he is responsible for the activities of the Departments and Divisions concerned with the operations,
- 45 maintenance and engineering of the Company's nuclear generating facilities as well as control over Industrial Relations, Marketing, Divisions and non-nuclear construction, production and engineering activities.
The Departments and Divisions and the job position responsible for activity within each are as follows:
1-8 Rev. 45 6/30/87 Commonwealth Edison
Production-Services',nTechnical. Services, and Licensing -
-Assistant Vice President (Licensing and Plant Support Services);
Nuclear; Fuel Services, Administrative Services, and Production c45
'TrainingL-Assistant Vice President (Training, Fuel,.and Administrative Services); and Nuclear Stations Division - Vice l
Presidents - Senior Vice President (Nuclear Operations)
Industrial Relations - Vice President
,5 Marketing - Vice President I
Divisions - Vice -President
- 45 Station Construction Department -
. Manager of Station Construction Operational Analysis, Materials Analysis, Environmental Affairs, Research,'~ Fossil Stations' Division, System Power Supply and
- 45 other Engineering Departments - Senior Vice President (Engineering)
The Vice President (or General Manager) (Divisions) is responsible for the activities of the six Operating Divisions and the Operating Manager.
These Divisions are assigned responsibility J
i for those activities concerned with distribution of power as well as service to customers and public relations within their respective i
geographical areas including operation and maintenance and inspection of electrical transmission and distribution facilities.
The Operating Manager's responsibility includes the Transmission and
. Distribution Construction Department which has functional responsibility and control for Division Substation Construction activities.
A Division Vice President is~ responsible for each Division.
A Division Operating Manager reports to the Division Vice President.
.The Division Operating Manager is responsible for Division Substation Construction and Division Operational Analysis activities..
Commonwealth Edison assigns to the General Purchasing
- 45 Agent, who reports to a Vice President, the responsibility for the procurement of:- services, spare parts, materials and equipment in l
accordance with the' purchase requisition and contract specifications, requirements and for obtaining the required quality assurance documentation for such items.
Corresponding responsibility for the procurement of nuclear fuel (including reprocessing) is assigned to the Manager of Fuel, who also reports
- 45 to the Vice President (Fuels & Budgets).
1.2 Organization The Commonwealth Edison Company organization as related to 0"ality Assurance, is shown in Figures 1-0 and 1-1.
Departmental and divisional organizations showing the Quality Assurance function is shown in Figures 1-2, 1-2.1, 1-3 and 1-6.
1.3 Scope Specific responsibilities for implementation of the Quality l
Assurance Program are assigned to the Commonwealth Edison Company organizational groups as outlined herein.
The scope of responsibilities involved in a nuclear project is divided into four Phases.
g I
l-9 l
Rev. 45 6/30/37 Commonwealth Edison
_g.
m Phase'I -
' Definitions of~ system design and quality requirements _and acceptance of the quality of j
design.
l{
Phase II-
. Verification that design and quality require-ments have been met during construction.
q l
Phase III-Baseline in-service inspection; preoperational 1
testing.
l Phase IV -
Operation, in-service inspection, maintenance, j
repair, refueling and station modifications, q
start-up testing and pre-operational testing.
j i
1,4 Engineering and Construction Responsibilities i
1.4.1 Engineering (Project Engineering and Cognizant Nuclear
- 45 Stations Engineering and Production Services Departments Station Projects Department including Project Engineering is organized as shown in Figure 1-4.
The other Engineering Departments are organized as shown in
- 45 Figure 1-3.
The Production Services Department has i
engineering support responsibility for Phase'IV.
j Project Engineering has responsibility for Phases I, II
~
and III.
The cognizant. nuclear stations Engineering
- 45 Department'also has responsibility for Phase IV.
For Phases I and II Project Engineering delegates and also coordinates various segments of these activities-with Project Construction, the cognizant nuclear.
- 45 stations Engineering Department and the Production Services Department, Station Construction Department, Licensing Department, Operational Analysis Department, Materials Analysis Department, Nuclear Stations Division and Project Operating.
For Phase IV station modifications design activities, the cogniant nuclear-
- 45 stations Engineering Department has responsibility for a
design and schedules and for obtaining assistance for their respective nuclear stations.
- 45 The Projects Engineering Manager, who reports to the Manager of Projects, has overall Project Engineering
- 45 1
responsibility and,.as applicable, assigns specific nuclear generating station project responsibilities to the cognizant Project Engineer, Project Engineering Manager or Project Field Engineering Manager for the respective construction projects.
The cognizant Project Engineer or. designee or Project Field Engineering Manager has engineering responsibility for the respective project and specifically supervises their respective responsible electrical, mechanical, structural and nuclear activities during plant design and construction. During plant operation, the respective Project Engineer in the c'ognizant nuclear
- 45 1
stations Engineering Department, has overall 4
engineering responsibility and specifically supervises the electrical, mechanical, structural and nuclear activities involving plant modifications.
Rev. 45 1-10 6/30/87 Commonwealth Edison
1.4.1 (Cont'd)
The respective Project Engineer directs and
]
coordinates the associated activities.under j
his or her scope of work.
The Project
(
Engineering Project Engineer.is responsible for the following responsibilities:
a.
Review and control the scope of work involving the electrical, mechanical, structural and instrumentation, and i
control designs of the NSSS vendor'and Architect Engineer to verify that appli-cable Safety Analysis Report (SAR),
regulatory requirements, ASME Code requirements, and design bases are properly translated into specifications, drawings, procedures and instructions.
b.
Review and accept the specifications, drawings, and scope for electrical, mechanical and structural material, equipment and erection work, prepared by the Architect Engineer and NSSS vendor, to verify inclusion of inspec-tion, testing and acceptance' criteria.
c.
Analyze bids, make purchase recommenda-tions, control expenditures and assure that necessary quality requirements.are included in purchase orders and contracts.
d.
Disposition of electrical, mechanical
}
and structural design changes.
1 e.
Review the Architect Engineer's evalua-(
tion of fabricator's and erector's detailed designs, drawings and work instructions for reasonableness and completeness.
f.
Review and approve resolution of noncon-formances relating to electrical, mecha-nical and structural portions of the generating station.
g.
Establish the plans for the prcopera-tional and start-up test programs.
h.
Coordinate the preparation and review L
of preoperational and start-up test procedures.
1-11 Rev. 28
- 28 3/16/84 Commonwealth Edison
(.
,of-the-results of.the preoperational and..
start-up testing.
Make recommendation for acceptance of test.results when results are.
judged satisfactory.
j.. Develop overall schedules, k.
Perform detailed design activities and issue design documents'in'accordance with
- 45 approved procedures.
The Project Field Engine'ering Manager is responsible for engineering design implementation, reviewing systems for modification and deficiencies, resolvir.g construction problems and coordinating and overseeing the Architect-Engineer field group plus, where assigned for review and comment of on-site contractor Quality Instructions and
~
Procedures and for review and evaluation of CECO nonconformances.
Similarly, once the nuclear unit has been issued a full power operating license and has by mutual agreement been turned over from the Manager of Projects to the Vice President
- 45 (Nuclear Stations Operations), the cognizant nuclear stations Engineering Department i
respective Project Engineer is responsible for the responsibilities listed above'as applicable for plant modification and completion of the pre-operational and/or start-up testing program.
The Production Services Manager has overall
- 45 Owner's responsibility for the Form N-3 Data.
Report and other CECO N type Data Reports including stamping responsibility for ASME Section III, Division 1 and 2 covering concrete containments.
The Production Services Manager
- 45 assigns the CECO responsibilities for the Form N-5 and C-1 Data Reports, including stamping, to the Project Manager during initial design and construction.
The Production Services
- 45 Manager assigns the NA and NPT responsibilities for Code adherence to the Station Manager in
- 45 connection with the extension of the corporate certificates to the respective nuclear stations.
- 45 1.4.2 The Quality Assurance Coordinator assigned to the
- 45 )
cognizant nuclear stations Engineering, Production Services and Project Engineering has the responsibility to assure that the following quality assurance activities are performed.
(Also see 1.4.7.1.A) a.
' Development of quality procedures to be used by the cognizant nuclear stations
- 45 Engineering, Production Services and Project Engineering in the Commonwealth Edison Quality Assurance Program.
1-12 Rev. 45 6/30/87 Commonwealth Edison
t:
1 1.4.2 (Cont'd) b.
Evaluation of contractors', including Architect Engineers', quality assurance programs.
c.
Acceptance of only acceptable contractors',
i including Architect Engineers', quality f
assurance programs.
d.
Audits of the design review system of 1
Architect Engineer and NSSS vendors.
- 45 e.
Audits of off-site contractors, as g
necessary, or requested.
j f.
Review of purchase documents (i.e.,
i specifications drawings, procedures and instructions for assurance of the inclusion of quality requirements.
- 45 g.
Review of fabricator and erector work instructions for inclusion of nondestruc-tive and electrical testing requirements.
1.4.3 The Architect Engineer is responsible to Project Engineering and, for operating nuclear plant modification, to the cognizant nuclear stations
- 45 Engineering Department and the Production Services Department for the mechanical, structural and electrical design of the plant and for the quality of that design (except for those portions of that design included within the scope of the Nuclear Steam Supply System (NSSS)).
In this context, the Architect Engineer performs an independent evaluation of vendor proposals, designs, vendor and contractor procedures, test reports
- 45 and design reports.
The Architect Engineer further performs an independent evaluation of the NSSS design.
The Architect Engineer is assigned responsibility for the document distribution for Phases I,
II and III of the job.
1.4.4 Station Electrical Engineering Department The Station Electrical Engineering Department will provide electrical engineering technical assistance to
- 45 the cognizant nuclear stations Engineering and the Production Services Departments, as requested, or assigned, by these Departments as well, similarly, for Projects Engineering.
l-13 Rev. 45 6/30/87 Commonwealth Edison
I 1.4.5 Construction Project Construction and Station Construction Department
~
The Station Construction Department is organized with a Manager, Construction Manager, Superintendents, Supervisors and Field Engineers as shown in Figure 1-2.
Project Construction, reporting to the Project Manager, is organized as shown on Figure 1-4 with a Site Construction Superintendent and Field Engineers.
The respective Site Field Engineer groups generally are headed by a supervising or lead type individual depending on the status and requirements of the project who, in turn, carries out the responsibilities of, and reports to, the Project Site Construction Superintendent or Construction Superintendent.
(A Site Quality Assurance Superintendent or Supervisor Quality Assurance is assigned to each construction site independent of the Station Construction Depsrtment for Phase II.)
1.4.5.1 The Project Manager assigns a Site Construc-tion Superintendent or Manager to a
- 40 construction site who has the following responsibilities:
a.
Advisor to Engineering for design suitabi-lity from a construction viewpoint.
b.
Coordinate requests for field revisions, c.
Receipt of items including furnishing necessary storage facilities.
d.
Assist Project Engineering in development of overall schedule.
e.
Verify conformance and completeness of contractor's installation or erection to specification requirements.
f.
Supervise and approve mechanical and structural construction tests, g.
Coordinate and provide assistance for electrical construction tests.
h.
Coordinate preoperational tests.
Similarly, during plant operation the Station Construction Department, Construction
- 40 Superintendent, or corresponding title for the *40 lead person is responsible for the responsibilities listed above, as applicable for plant modifications.
1-14 Rev. 40 2/28/86 Commonwealth Edison
I 1.4.5.2 'The Site' Construction Superintendent, or Manager, Construction Supervisor, or Field Construction Engineer, as appropriate, is J
responsible for coordinating and directing-Phase II of the Program activities, for assuring procurement requirements are fulfilled by suppliers, and for I
construction at the site.
The Station l
Construction Department and Projects
- 45 l'
Department provide construction assistance e
and expertise to the total program including plant modifications under Phase IV.
The Project Manager or Manager of Station
- 45 Construction is assigned ASME Section III, Division 2 Constructor responsibilities.
The Manager of Station Construction, when applicable, has the responsibility for maintaining a Level III person on Staff responsible for personnel. development and qualification and for the performance to the requirements for concrete inspection as required by rules established in Section III, Division 2 of the ASME Code.
1.4.6 Operational Analysis Department a'nd Materials ~
Analysis Department The Operational Analysis Department and Material Analysis Departments are organiz,hd as shown in Figure-1-5.
- 1. 4. 6.1 ' The Operational Analysis Manager has the following responsibilities including functional control of.bivision and Project Operational. Analysis epartment:
a.
Participate in re0iew of design specifi-cations to verify'the inclusion of
~
adequate electric'l testing a
requirements as directed.
b.
Prepare procedurps and conduct electrical const:ruction tests as directed.
t c.
Participate in,the preparation and review of preoperational and start-up test procedures, as directed.
d.
Participate in,and coordinate preoper-ational and start-up testing, as directed.
1-15 Rev. 45 CommonNaltNh5 son
e.
Maintain Commonwealth Edison Company off-site testing facilities and equipment required to fulfill the Department responsibilities.
f.
Provide specialized testing services and equipment analysis such as instrument and equipment calibrations (traceable to national standards).
The Operational Analysis Department provides specialized field testing services through its technical staff specialists, standard-izing and calibration services and retention of related quality assurance documentation.
Also, the Department is responsible for inspection and proof testing of electrical generation, transmission and distribution equipment.
1.4.6.2 The Materials Analysis Manager has the following responsibilities involving chemistry, metallurgy, nondestructive examination and ulbration activities:
a.
Participate in review of design specifications to verify proper selection of materials as directed.
b.
Prepare procedures and conduct or contract tests as directed.
c.
Maintain SNT-TC-1A Level III person on staff responsible for personnel and procedure development and qualification to ASP.E Code requirements for nondest;uctive examination.
d.
Maintaid 1 commonwealth Edison Company off-sirs testi, facilities and j
equipnent required to fulfill the j
Dcpartment responsibilities.
e.
Provide necessary assistance and expertise for baseline and in-service inspection.
f.
Provide or contract specialized testing services and equipment analysis such as for evaluation of materials.
1-16 Rev. 28 *28 3/16/84 Commonwealth Edison
The Materials Analysis Department provides
~
or. contracts specialized chemistry,
' metallurgy, nondestructive examination and vibration analysis services and materials expertise through its technical staff specialists.
The Company Level'III NDE person is assigned to this Department.
1.4.6.3 The Quality Assurance Coordinator assigned to the Operational Analysis.and Material Analysis Departments has the responsibility to assure that the.following quality assurance activities are performed:
a.
Calibration is performed on test and measurement equipment as required.
~
b.
Auditing is performed of destructive and nondestructive testing as directed, c.
Nondestructive test personnel qualifica-tions records are maintained.
d.
Auditing is performed of calibration services vendors.
1.4.7 Director of Quality Assurance (Engineering-Construction)
The Director of Quality Assurance (Engineering-Construction) reports to the Manager Quality Assurance and is responsible for administration of the Commonwealth Edison Company Quality Assurance Program Requirements and Procedures established for the design and construction phase of nuclear power generating stations.
Specifically, he will direct the efforts of the Construction Site Quality Asstrance activities and provide functional direction to each Quality Assurance Coordinato'r assigned to the cognizant nuclear stations
- 45 Engineering, Production Services, Project Engineering, Materialr Analysis and Operational Analysis Departments.
He maintains a cognizance of the Operations' portion of the Quality Assurance Program to determine that it interfaces with the design and construction quality assurance phases.
He, or a designee, shall serve as liaison with quality assurance organizations of the NSSS Vendor, Architect Engineer, Authorized Inspector and Contractors - as necessary - to verify that compliance with the applicable Codes,
' Standards and Regulations is met.
This Director of
- 45 Quality Assurance (Engineering-Construction) will regularly inform the Manager. Quality Assurance of significant quality assurance developments and problem
- 45 4
1-17 Rev. 45 6/30/87 Commonwealth Edison
areas.
The Director of Quality Assurance (Engineering-Construction) has sufficieat authority to identify problem areas and require corrective action.
1.4.7.1 Site Quality Assurance, Superintendent (Engineering-Construction)
Each Site Quality Assurance Superintendent reports to the' Director of Quality Assurance (Engineering-Construction) or, where this Superintendent job position responsibilities are combined into such Director position, to the Manager Quality Assurance and.is responsible for the quality activities within his specific department.
He.is responsible to observe and inform the Director of Quality Assurance (Engineering-Construction), or the Manager Quality Assurancx where applicable, of any deficiency involving required Safety Analysis Reports, Quality Assurance Manual Reports, design reports, construction reports and test reports.
Reporting to such Superintendents, where established as site activities deem necessary, are the site Supervisors Quality Assbrance.
The Site Quality Assurance Superintendent or
-other established lead person, as applicable, is responsible for reviews and audits to assure that the above requirements are met and that nonconformances are resolved.
A.
Engineering - In addition to the responsibi-lities stated herein, under Section 1.4.2, the Quality Assurance Coordinator assigned to the cognizant nuclear stations Engineering,
- 45 production Services and project Engineering Departments is responsible for surveillance and audit of Engineering activities involving construction projects and operating nuclear plants for conformance to requirements.
He maintains surveillance of required documenta-tion of modifications activities at operating stations where Station Nuclear Engineering Department responsibility is involved.
His responsibilities are achieved through project review, surveillance and day-to-day involvement plus by support, involvement and action, functionally, by the Director of Quality Assurance (Engineering-Construction), and by the Manager Quality Assurance.
1-18 Rev. 45 CommonweekthEdison
--_----__.-_---_____u
B.
Operational Analysis and Materiais Analysis -
The Quality Assurance Coordinator assigned to the Operational Analysis Department and the Materials Analysis Department is respon-sible for assuring that calibration proce-dures and records are maintained for Nuclear Station Test and Measurement equipment.
He also maintains surveillance of required documentation of their respective testing and inspection activities.
His responsi-bilities are achieved essentially in the same manner as stated for the Quality Assurance Coordinator assigned to Engineering except he reports to a Quality Assurance Superintendent and, in turn, the Manager of Quality Assurance with functional
- M administration by the Director of Quality Assurance (Engineering-Construction).
C.
Construction Site - The Site Quality Assur-ance Group will vary with the volume of quality oriented activity at the site.
Generally, the number will vary from one to twenty or more; a lt'noug h, in the pre-con-struction and early and closing stages of construction a Supervisor Quality Assurance or a Site Quality Assurance Coordinator or Engineer may perform these activities alone.
The Site Quality Assurance Superintendent or other site Quality Assurance designee is responsible for assuring necessary procure-ment requirements are provided in CECO site procurement packages involving safety-related and ASME Code purchases, off-site vendor inspections and surveillance, surveillance of site contractor quality activities, compliance of material and equipment with procurement document requirements, mainten-ance of quality records filed at the site and direction of the site quality -assurance group activities.
These responsibilities will be achieved using Quality Assurance Engineers or Inspectors through review, surveillance and audit activities, continued monitoring and day-to-day involvement.
The Site Quality Assurance Superinter.' dent and, in turn, the Supervisors Quality Assurance reporting to such Superintendents have the responsibility that the following quality assurance activities are performed:
1-19 Rev. 44 2/25/87 Commonwealth Edison
a.
Development and approval of site contractor
-construction quality control procedures.
b.
Review and approval of site contractor quality assurance programs including site
{
procedures.
i c.
Advise'the appropriate Engineering organi-zation'of Bidder Quality Assurance capabilities when requested.
d.
Maintain surveillance of site contractors to verify conformance-to approved quality control programs and procedures by review, surveillance and audits.
e.
Assure accumulation, filing and mainten-ance of quality assurance documents and records required for site construction by surveillance and audit.
f.
Review and acceptance of nondestructive test documentation.
g.
Identification and maintenance of files for site nonconforming items and follow-up and monitor of corrective action required for disposition of site nonconformances.
h.
Maintenance of calibration records for test equipment involved in site construction activities through surveillance and audit.
i.
Safekeeping of quality assurance documen-tation during construction by surveillance, j.
Surveillance and approval by Quality Assur-ance of material receiving reports including assurance required corrective actions are completed.
k.
Review by Quality Assurance of on-site contractor surveillance reports for quality problems and completion of corrective actions.
1.
Quality Assurance audit of on-site contractors.
m.
Review and approval of site procurement packages involving safety-related and PSME Code purchases to assure necessary require-l
.ments are provided and the proposed vendor (s) is acceptable.
1-20 Rev. 28
- 28 3/16/84 Commonwealth Edison
l n.
Results of electrical construction tests are reviewed.
l.4.8 Director of Quality Assurance (Operations)
- 4 The Director of Quality Assurance (Operations) reports
- 45.
to the Manager Quality Assurance and is responsible for administration of the Commonwealth Edison Company Quality Assurance. Program Requirements and Procedures established for the operating phase of nuclear power generating stations.
Specifically, he will direct the efforts of the Station-Quality Assurance Superintendents
- 45 and, in turn, the Quality Assurance Engineers or Inspectors covering quality assurance for operating activities.
This Director of Quality Assurance will regularly inform the Manager Quality Assurance of
- 45 I
significant quality assurance developments, activities and problem areas.
The Director of Quality Assurance (Operations) will inform the Vice Presidents (Nuclear Stations Operations), Nuclear Fuel Services Manager and, where'a'pplicable, the Manager of Fuel of significant quality assurance questions and problems related to fuel fabrication.
The Director of Quality Assurance (Operations) has sufficient. authority to identify
- 45 problem areas and require corrective action.
1.4.8'.1 Nuclear Fuel Fabrication Inspector The Nuclear Fuel Fabrication Inspector has the responsibility for surveillance of fuel fabrication at vendor's plant, overview of the
- 45 fuel control at the nuclear stations and keeping abreast of fuel assembly problems and concerns.
He reports to the' Director of Quality Assurance (Operations).
1.4.9 Director of Quality Assurance (Maintenance)
The Director of Quality Assurance (Maintenance) reports to the. Manager Quality Assurance and is responsible for
- 45 administration of the Commonwealth Edison Company Quality Assurance Program Requirements and Procedures established for the maintenance, modification, in-service inspection and Stores activities at Operating Nuclear Power Stations.
This Director will regularly inform the Manager Quality Assurance of significant
- 45 Quality Assurance developments, activities and problem areas.
The Director of Quality Assurance (Maintenance) has sufficient authority to identify problem areas and require corrective action.
1-21 Rev. 45 6/30/87 Commonwealth Edison
~
'l.4.10 Station Quality Assurance Superintendent
~
The Station Quality Assurance Superintendent reports to the Director of Quality Assurance (Operations) on
- 45 t
quality assurance. operating activities and to the Director of Quality Assurance-(Maintenance) on quality assurance activities involving modifications, maintenance, in-service inspection and Stores-activities for operating nuclear power stations.
The respective Quality Assurance Engineers or Inspectors assigned to the station report to the Station Quality Assurance Superintendent.
I.
The Quality Assurance Engineers or Inspectors for operating assigned to a station have authority and responsibility for-the surveillance and audit of:
a.
The. preparation and revision of the station procedures for administration and operations.
b.
Implementation of the Operations portion of'the Quality Assurance program.
c.
The completion of documentation showing that the required inspections and tests were performed, d.
The completion of reported corrective action.
e.
The incorporation of approved engineering changes into station operating procedures.
II.
Quality Assurance Engineers and Inspectors for maintenance, modification, in-service innpection and Stores activities assigned to the stations have authority and responsibility for surveillance and i
I audit of:
a.
Implementation of the modification and mainten-ance portion of the Quality Assurance program.
b.
The preparation and revision of the Station procedures for the modification and maintenance.
c.
The completion of documentation showing that the required inspections and tests were performed for modification, maintenance and material receipts.
He shall also review and approve receiving inspection documentation.
1-22 Rev. 45 6/30/87 Commonwealth Edison
~
1 d.
The proper and satisfactory-completion of J
modification, maintenance and reported'correc-
+
tive action.
He.shall also review and' approve such completion and corrective action..
e.
The incorporation of approved engineering changes into maintenance and operating
{
procedures.
f.
Completion of ASME Code requirements, g.
In-service inspection and Stores activities.
h.
Adherence to Technical Specification require-
~
1 ments where involved with modification, main-j tenance and in-service inspection activities.
1.5 NUCLEAR OPERATIONS RESPONSIBILITIES NUCLEAR STATIONS DIVISION
- 45 1.5.1 Vice Presidents (Nuclear ~ Stations Operations)
- 45 The Commonwealth Edison Company production stations are divided into two Divisions - Fossil and Nuclear with the
- 45 Nuclear Stations Division being divided into two groupings, one consisting of the three Pressurized Water Reactor nuclear stations and the other of the three Boiling Water Reactor nuclear stations.
The respective Vice Presidents in charge of the Fossil Stations Division and of each grouping of stations in the Nuclear Division are responsible for the safe and reliable operation and maintenance of the plant assigned to his division.
The Vice Presidents (Nuclear Stations Operations) report
- 45 to the Senior Vice President (Nuclear Operations) and have responsibility for managing the nuclear generating stations and the engineering activities associated with their respective Station grouping.
The Vice Presidents (Nuclear Stations Operations) are
- 45 l
responsible for approval of requisitions for the l
procurement-of parts, components and materials, support I
services and work assistance functions involving l
maintenance, modifications and special tasks from vendors and contractors.
1-23 Rev. 45 6/30/87 Commonwealth Edison it
____________o
A!
1.5.1.~1 GENERAL MANAGERS (NUCLEAR STATIONS OPERATIONS) 45 The-two General Managers (Nuclear Stations Operations)
- 45 are shown in. Figure 1-6.
These' General Managers report to the respective Vice Presidents (Nuclear Stations Operations)'and each has responsibility, as assigned, for functionally directing their assigned nuclear generating stations, through the respective Station Manager, in a safe and efficient manner and in accordance with Company procedures,.NRC Technical Specifications and governmental regulations.
As assigned by the Vice President, they have functional
- 45 control responsibility for coordinating station policies, providing. support to operating station personnel, coordinating unit outages with Power Supply, and providing functional direction to the Station Managers regarding day-to-day matters.
They also act on the behalf of the cognizant Vice President for other.
- 45 items'as delegated to them and during periods when the cognizant Vice President is unavailable.
- 45 They are also functionally responsible for obtaining and
- 45 authorizing the use of services, or for required liaison or interface with other Commonwealth Edison Company departments such as:
Accounting, Engineering, Construction, Technical Services, Industrial Relations,
- 45 Licensing, Quality Assurance, Nuclear' Safety, Materials Analysis and Operational Analysis.
1-24 Rev. 45 6/30/87 l
l I
l l
~
i I
Commonwealth Edison L
1.5.1.1 GENERAL MANAGERS (NUCLEAR STATIONS OPERATIONS) (Cont'd) c45 Where assigned, they provide liaison between the
- 45 Regional Nuclear Regulatory Commission's Director of the Office of Inspection and Enforcement and the respective
- 45 Nuclear Division Departments.
They are involved functionally, through the Station
- 45 Managers of each assigned power station, in the direction of such activities as operations, maintenance, station security, refueling, authorization of modifications performed at the Station, performance monitoring and investigation, compliance with procedures, regulations and licenses, personnel selections,. training and related activities.
- 45 Their responsibilities include coordinating operating
- 45 and maintenance policies and providing functional direction regarding day-to-day matters.
They maintain industry contacts with nuclear stations of
- 45 other companies and transmit information from them regarding operating problems to Commonwealth Edison's Nuclear Stations.
They have common equipment and system problems communicated among stations in a timely manner.
They have Deviation Report events, Quality Assurance audits, NRC inspection reports and other significant events and functions reviewed for trends, effects on other units and corrective actions.
- 45 i
t l
l 1-25 Rev. 45 l
i 6/30/87 l
l 1
Commonwealth Edison f
)
}
L
- 1. 5.1. 2.1 -
STATION MANAGER c45 Each nuclear generating station is managed, through the Production Superintendent, the Services Superintendent ~and the Industrial Relations Supervisor, respectively, by a Station Manager who is responsible for the 1
management of the station including. industrial j
relations, planning, coordination, direction of 1
the operation, maintenance, refueling.and H
technical activities.
The Station Manager is i
responsible for Phase III and IV and compliance q
with the Station's NRC Operating license, l
government regulations, ASME Code requirements O
and the Company Quality. Assurance program.
He I
also authorizes the use of procedures contained in the Station Procedures Manual, and is responsbile for final approval and distribution of station reports. _He may delegate these responsibilities as appropriate to the appropriate Superintendents.
Prior to issuance of the operating license, the Production organization provides personnel to support activities of an operating nature where the preoperational test activities, including reviews of test data, are assigned to a i
sepa' rate organization in Projects at the construction site.
Repair and equipment maintenance needing technical review for substitution of equipment are reviewed by the Sthlion Technical Staff and completed as maintenance activities under station management.
He supervises the Station's on-site review function as provided in the Administrative Section 6.0 of the Technical Specification.
During periods when the Station Manager is unavailable, he shall designate this responsibility to an established alternate who satisfies the ANSI N18.1 experience requirements for plant manager.
l 1.5.1.2.1.1 Industrial Relations Supervisor
- 45 The Industrial Relations Supervisor reports to the Station Manager and performs various personnel activities as assigned.
1-26 Rev. 45 6/30/87 Commonwealth Edison
l.5.1.3.0 Production Superintendent Reports to the Station Manager.
Manages operations and maintenance activities including the day-to-day operations of the station, both during operating and during outages.
The Production Superintendent authorizes modifications to the Station after the issuance of an operating license and completion of preoperational testing.
He, or his designee, forwards requests for modifications to the
- 45 cognizant nuclear stations Engineering Department and the Production Services Department.
Also, the Production Superintendent is responsible for controlling the in-plant work of non-station personnel.
Reporting to him are the Assistant Superintendent Operating and Assistant Superintendent Maintenance.
1.5.1.3.1 Assistant Superintendent Operating Responsibility for the day-to-day operating and refueling activities for the Station is delegated to the Assistant Superintendent Operating. Reporting to him are the Station Operating Engineers and Shift Engineers, plus the Fuel Handling Foremen and the Stationmen Foremen.
1.5.1.3.1.1 Operating Engineers The Operating Engineers are responsible for the operation of the mechanical and electrical equipment and certain common plant systems, such as fuel handling and radioactive waste processing, assigned to them by the Assistant Superintendent Operating. They are responsible for recommending maintenance for such equipment and for authorizing functional acceptance tests to be conducted by Operating and Technical Staff personnel.
1.5.1.3.1.2 shift Engineer The Shift Engineer on duty is responsible for operating the plant in l
compliance with the station Operating License and the Station Operating l
Procedures.
During his shift, the Shift Engineer is in charge of the entire plant operation and is responsible for the plant being operated ir, a safe and reliable condition.
He reports to the Assistant Superintendent Operating.
He receives direction from the Operating Engineers.
1-27 Rev. 45 6/30/87 Commonwealth Edison
l.5.1.3.2 Assistant Superintendent Maintenance
,x The Assistant Superintendent Mainter.ance is
- x responsible for directing the maintenance, including repair, of all mechanical and electrical equipment including instrumentation.
His responsibility includes planning work, providing on-the-job training of maintenance personnel, maintaining calibration listing for maintenance, arranging for the maintenance work and its inspection to be performed and initiating requisitions for the procurement of tools, materials, equil ment and parts from vendors and services from contractors.
The Station Stores Supervisor also reports to him.
1.5.1.3.2.1 The Master Instrument Mechanic l
The Master Instrument Mechanic is responsible for maintaining and repairing instrumentation at the Station.
His responsibility includes planning work, providing on-the-job training of instrument personnel, setting up instruments for tests, maintaining listing of calibrated instruments, arranging for the instrument maintenance work and its inspection to be performed and initiating requi-sitions for the procurement of instruments and parts from vendors and services from contractors.
The Master Instrument Mechanic reports to the Assistant
- x Superintendent Maintenance.
1.5.1.3.2.2 Master Mechanic The Master Mechanic is responsible for maintaining and repairing mechanical equipment and structural equipment at the Station.
His responsibility includes planning work, providing on-the-job training of mechanical maintenance work and its inspection to be performed, and initiating requisitions for the procurement of mechanical and structural parts and components from vendors and services from contractors.
The Master Mechanic reports to the Assistant Superintendent Maintenance.
- x l-28 Rev. 34 4/10/85 Commonwealth Edison
1.5.1.3.2.3 Master Electrician
~
The Master Electrician is responsible for maintaining and repairing electrical equipment at the Station.
His responsibility includes planning work, providing on-the-job training of electrical maintenance work and its inspection to be performed, and initiating requisitions for the procurement of electrical parts and components from vendors and services from contractors.
The Master Electrician reports to the Assistant Superintendent ex Maintenance.
1.5.1.3.2.4 Station Stores Supervisor The Station Stores Supervisor reports to the Assistant Superintendent Maintenance.
- x The Station Stores Supervisor receives functional direction, which includes all Stores Instructions, from the General Supervisor of the production Stores who reports to the Manager of production Services in the Fossil Division.
The Stores Supervisor is responsible for the administration of the Station Storeroom including all procurement, receiving inspection, storing and issuing of capitalized spare parts, materials, supplies and equipment.
His responsibilities include coding of all stocked items; verifying the receipt af Quality Assurance Documents specified in the procurement documents for spare parts, welding materials, other materials and equipment; maintaining inventory records for all stocked items at the station; and complying with special handling and storage
{
instructions.
I 1.5.1.4 Services Superintendent l
The Services Superintendent reports to the i
Station Manager and manages intra-station services and coordinates technical services l
provided to the station from outside the station.
Reporting to him are: (1) Assistant
- x Superintendent Technical Services, (2) Office Supervisor, (3) Station Security Administrator, (4) Training Supervisor, and (5) Compliance Administrator.
l-29 Rev. 34 4/10/85 Commonwealth Edison
- o ;
~1.5'.'1.4.1 Assistant Superintendent Technical Services Reports to:the Services Superintendent.
Responsibility for the day-to-day Technical Staff, Radiation Chemistry,-and Quality Control Departments' activities at the Station.
The Supervisors of the' respective departments report to him.
Cognizant. nuclear stations
- 45 Engineering Department representatives assigned to the station will report to-this Assistant Superintendent.
1.5'.l.4.1.1 Technical Staff Supervisor The. Technical Staff Supervisor-'provides technical support for plant operations, refueling, maintenance, modifications and-in-service inspection and evaluates process data.and equipment performance and adequacy of station procedures.
He reports.to and makes recommendations and advises the Assistant Superintendent Technical Services.
with respect to quality 1 assurance.
He has the responsibilities and authority as described in Section 6.0 of the Technical Specifications for' implementation of the on-site review function.
He is also responsible for the following:
a.
Witnessing of assigned testing for verifying' completion of modifications and equipment maintenance, b.
Verification of incorporation of approved engineering changes into station maintenance and-operating procedures.
c.
Verification of completion of reported corrective action.
1-30 Rev. 45 6/30/87 l
i Commonwealth Edison j
J
1.5.1.4.1.2
-Quality Control Supervisor The station Quality Control Supervisor reports to the Assistant'
- 34 Superinte'ndent Technical. Services and is responsible for the quality control activities at the Station such as:
reviewing drawings, specifications, Maintenance /
Modification Procedures and requests forLpurchase for inclusion of applicable quality requirements;.
performing receiving inspection for ASME and safety-related incoming materials.and. items and' inspection-of fabrication.and'insta11ation activities; and having nondestructive examination and other testing performed as required.
1.5.1.4.1.3 Rad / Chem Supervisor The Rad / Chem Supervisor is responsible for directing Health Physics, Chemistry, and' Radio-chemistry activities.
The Rad / Chem Supervisor is responsible for the formulation and.
implementation of a Station Radiation Protection Program to maintain occupational radiation exposures as low as reasonably achievable (ALARA).
Although the 4
Rad / Chem Supervisor reports to the Assistant Superintendent Technical
- N4 Services, the Rad / Chem Supervisor does have direct recourse to the Services Superintendent or Station Manager in. order to resolve
- 34 questions related to the conduct of the Radiation Protection Program.
1.5.1.4.2 Office Supervisor The Office Supervisor is responsible for i
directing the activities of the station's clerical staff and for maintaining files of quality assurance documents assigned to him.
He reports to the Services
- )4 Superintendent.
1 1-31 Rev. 34 4/10/85 Commonwealth Edison
_]
1.5.1.4.3 Station Security Administrator The Station Security Administrator is responsible for directing the station's security plan activities and supervising the on-site security activities.
He reports to the Services Superintendent.
1.5.1.4.4 Training Supervisor The Training Supervisor is responsible for the training and retraining of operating, technical support and maintenance personnel.
- 45 His responsibility includes planning, scheduling, preparing, presenting and documenting completion of training courses.
1.5.1.4.5 Compliance Administrator The Compliance Administrator reports to the Services Superintendent.
- Monitors, investigates and reports to Senior Station J
Management Compliance with regulatory requirements.
Activities generally include coordination of off-normal performance event investigations, Regulatory Performance Improvement Program implementation, trending regulatory performance parameters, etc.
1.6 Nuclear Services Responsibilities 1.6.1 Assistant Vice President (Licensing and Plant Support
- 45 Services)
- 45 The Assistant Vice President (Licensing and Plant Support Services) reports to the Senior Vice President (Nuclear Operations) and has the responsibility for managing technical support services provided to the operating nuclear stations and the nuclear licensing activities.
He administers and controls these services through the managers who report to him (See Figure 1-6).
The technical services include engineering services, performance, and technical activities assessments, radiation protection, maintenance, emergency planning, operational chemistry, radioactive waste disposal, and station field support.
Reporting to this Assistant Vice President are the Technical Services Msnager, Production Services Manager and Licensing Manager.
1.6.1.1 TECHNICAL SERVICES MANAGER
- 45 The Technical Services Manager is shown in Figure 1-6.
He
- 45 has responsibility for providing needed technical support for the stations such as in the areas of operational chemistry, radiochemistry, radioecology, radwaste, emergency planning and radiation protection.
The r.adiation inspection responsibilities include insuring that Company Radiation Protection Standards and Procedures are effectively utilized and maintained.
This involves the ALARA program, NRC interface, and protection guideline and procedure review.
l-32 Rev. 45 6/30/87 Commonwealth Ed! son c
1.6.1.2 PRODUCTION SERVICES MANAGER
- 45 The' Production Services Manager is shown in Figure 1-3.
He
'45 is responsible for functional direction of, and assistance in, maintenance and engineering services activities for the nuclear stations.
As to maintenance support, he is responsible for providing
- 45 functional direction to the Production Superintendent and Assistant Superintendent Maintenance regarding maintenance activities, forced outages, scheduled outages and refueling operations plus an effective maintenance program for ALARA radiation exposures.
Other services involve fire protection, computer applications and NPRDS.
For Production Services responsibilities, see Sections 1.1 and 1.4.
1.6.1.3 LICENSING MANAGER
- 45 The Licensing Manager, basically, has responsibility for
- 45 the licensing activities involving the Nuclear Regulatory Commission as well as activities with the Illinois.
Department of Nuclear Safety (see Figure 1-6).
He administers and controls the monitoring and investigations of compliance with regulatory requirements and the reporting to various levels of management.
Other
. activities generally include coordination of off-normal performance event investigations, Regulatory Performance Improvement Program implementation, trending regulatory performance parameters, interfacing with the Nuclear Regulatory Commission, etc.
1.7 NUCLEAR ADMINISTRATIVE SUPPORT RESPONSIBILITIES
- 45 1.7.1 ASSISTANT VICE PRESIDENT (TRAINING, FUEL, AND
- 45 ADMINISTRATIVE SERVICES) e f
This Assistant Vice President reports to the Senior Vice
- 45 l
President (Nuclear Operations) and has the responsibility for managing training, nuclear fuel and administrative I
support services to the operating nuclear stations.
He administers and controls these services through managers who report to him (see Figure 1-6).
These are the Production Training Manager, Nuclear Fuel Services Manager and Administration Manager.
1.7.1.1 PRODUCTION TRAINING MANAGER
- 45 The Production Training Manager is shown in Figure 1-6.
He
- 45 directs the activities at the Company's Production Training Center and is responsible for a broad range of training services including license operator training, simulator training, maintenance training and other management and employee training programs in support of nuclear and other operations and functional activities in the Company.
1-33 Rev. 45 6/30/87 Commonwealth Edison
i 1.7.1.1 PRODUCTION TRAINING MANAGER'(Cont'd)-
, 845 Also, the production' Training Department documents training
- 45 needs, including Quality Assurance program training needs; prepares Training Standards to document training requirements for production area personnel; ensures availability of training programs to satisfy training requirements; monitors training scheduling activities; conducts training programs; maintains appropriate training records; and prepares and implements program evaluation instruments.
1.7.1.2 NUCLEAR FUEL SERVICES MANAGER
- 45 I
The Nuclear Fuel Services Manager is shown in Figure 1-6.
- 45
)
j The Nuclear Fuel Services Manager is responsible for I
providing corporate technical direction and support on fuel design and refueling activities such as the development of fuel loading patterns, refueling schedules, new fuel j
procurement and fuel performance. analyses, safety analyses 1
and-trending.
1.8 Director Corporate Security - Nuclear Securitl
- 45 l
This Director for nuclear security reports to the Executive
- 45 Vice president and is shown in Figure 1-6.
The Director is responsible for insuring that security programs at the nuclear power stations effectively meet all commitments to and the' regulations of the Nuclear Regulatory Commission.
- 45 1.9 System power Supply Department
- 45 The System power Supply Manager reports to the Senior Vice
- 45 president (Engineering) and is responsible for managing the bulk power system with the objectives of safe operation,
{
reliable service and efficient utilization of Company-owned
]
production facilities.
1.9.1 The Manager System Power Supply has the following
- 45 responsibilities:
a.
Scheduling power generation.
b.
Purchase and sale of power from and to other utilities.
l c.
Coordinating the operation of the Common-wealth system with the MidAmerica Interpool Network and other interconnected utilities.
d.
Final scheduling of outages for generating stations for corrective and preventative maintenance.
1-34 I
i
(
Rev. 45 6/30/87 Commonwealth Edison L______-----_-____----
1 j
,/1.10 Production Stores Department og The Production Stores Administrator has the following nuclear maintenance Production Stores responsibilities:
a.
Control of spare parts inventory; j
b.
Coordinating. procurement of spare parts and materials and assuring that technical and quality assurance requirements are specified in procurement documents; and c.
Liaison.with company stations and departments, manufacturers and other utilities on spare parts matters.
The Production Stores staff, in particular,-review station i
purchase requisitions for safety and ASME Code related spare parts, material and equipment to assure that requirements for Quality Assurance are specified as required and that Stores Code Numbers are assigned to spare parts to be stored at the station.
1.11 Manager of Nuclear Safety
- 45 The Manager of Nuclear Safety reports to the Chairman and President and receives day-by-day functional direction from the Senior Vice President (Nuclear Operations). This
- 45 Manager supervises the Off-Site Review Group and On-Site Nuclear Safety Groups.
The primary responsibilities of the Manager of Nuclear Safety'are to:
a.
Interpret, integrate, generalize, and analyze information from within and outside.the Company to discern patterns in designs, components, and procedures which affect nuclear safety.
.b.
Promptly report any unsafe plant conditions or practices to the Chairman of the Company, Assure findings and recommendations of the Off-Site c.
Review Staff and the On-Site Nuclear Safety Groups are satisfactorily resolved.
l d.
Assure that the operating experience from within and outside the Company is assessed and lessons learned are factored into Edison's plant operations.
e.
Initiate recommendations to improve safety at nuclear plants.
f.
Review the various phases of nuclear safety (design, construction, operation, and maintenance) to provide for integration of all safety related considerations.
1-35 Rev. 45 6/30/87 CommonweaHh Edison
_ _ _ = _ - _ _ _
s
-1.12 Purchasing' Responsibilities
- 45' l.12.1 Manager of Fuel I
The Manager of Fuel is responsible for Commonwealth's 1'
procurement of nuclear fuel to specifications furnished l
by the Nuclear Fuel Services Department.
He reports to l:
the Vice President (Fuel & Budgets) on matters involving
]
such fuel.
1 l
l 2.0 Division Operations' Responsibilities 2.0.1 Substation Construction Department
)
The Substation Construction Department performs electrical modifications at nuclear generating stations y
as directed by.the Station' Superintendent or designee or.
the cognizant nuclear stations Engineering Manager or
- 45
?
Production Services Manager or designee, and in e
accordance.with the provision of the Quality Assurance Manual.- Substation Construction Implementation Procedures and Site Specific Procedures are used to control specific processes and procedures unique to electrical construction and installation.
d i
j I
I 1-36 i
Rev. 45 i
6/30/87 1
CommonweaHh Edison I
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- 2. QUALITY ASSURANCE PROGRAM The Commonwealth Edison Company has extensive er.perience with the development, scheduling, design, construction and oreration of electric generating facilities.
It has pioneered in commercial nuclear power.
Commonwealth Edison Company and its consultants and vendors have established designs and specifications for compliance with applicable regulations, ASME Code and National Standards to assure installations of utmost safety and reliability.
Commonwealth Edison Company has attained qualified equip ment vendors and contractors through experience, evaluation at vendor plants and site surveillance during plant erection.
These efforts provide assurance that compliance with applicable design specifications and codes is maintained and a high level of reliability is achieved.
2.2 Policy It is the policy of Commonwealth Edison Company to assure a high degree of functional integrity of the equipment, structures and safety-related systems of its nuclear generating facilities, the performance of which are essential to the prevention of nuclear accidents that could cause undue risk to the health and safety of the public, or to the mitigation of the consequences of such accidents in the unlikely event they should occur.
These systems, equipment, and structures will be identified, designed, fabricated, erected, tested and operated to the criteria and requirements of ASME Boiler and Pressure-
. Vessel Code Sections III and XI, as referenced in the SAR applicable to I
a specific unit at the time of engineering, construction and major modifications, Appendix B to 10CFR50, Subpart H to 10CFR71, and the mandatory requirements of ANSI /ASME NOA-1-1983 (Regulatory Guide 1.28 Rev. 3 Dated 8/85) with the provision that CECO suppliers / vendors maintain a quality assurance program which satisfies ANSI /ASME, NOA-1-1983 or the ANSI /ASME N45.2 series of standards, ANSI N45.2 Standards not covered by ANSI /ASME NOA-1, and N18.7 Standards.
The schedule for completion of the changes to applicable procedures and other affected documents by each station to reflect the commitment to NQA-1, is aligned to the next renewal of the ASME Certifications at the respective Nuclear Power Stations:
Quad Cities -
May, 1987; LaSalle - November, 1987; Zion - January, 1988; Dresden -
+45 March, 1988; Byron - July, 1988; and Braidwood - December, 1988.
With the achievement of these scheduled changes by the respective stations, the below listed commitments to Regulatory Guides 1.28, 1.58, 1.64, 1.74, 1.88, 1.123, 1.144 and 1.146, or to specific identified N45.2 standards consolidated into NQA-1, will no longer apply.
Until attainment, the current commitments shall continue to aoply to each respective station as listed below.
Also, Commonwealth Edison commits to comply with 10CFR Part 21
" Reporting of Defects and Noncompliance" and with the Regulatory position of the following Regulatory Guides and the requirements of the following ANSI Standards as listed for each station.
2-1 Rev. 45 6/30/87 Commonwealth Edison
v -
4 I.
Dresden, Quad cities and Zion Nuclear Power Stations 1.28 (Safety Guide 28 - 6/72): 1.30 (Safety Guide 30 8/72)-
1.33 (Safety Guide 33 - 11/72): 1.37 - 3/73: 1.38 - 3/73: 1.39
- 3/73: 1.54 - 6/73: 1.58 - Rev. 1; 1.64 10/73: 1.74 - 2/74:
1.8 (Safety Guide 8 - 3/71); 1.146 - Rev. 0 8/80: ANSI N45.2.8-74 (Draft 3, Rev.
3, N45.2.9-74 (Draft 15, Rev.
O, 4/74); ANSI N45.2.12-74 (Draft 3, Rev. 4 2/74); ANSI N45.2.13-74 (Draft 2, Rev.
4, 4/74)
II.
LaSalle County Nuclear Power Station 1.28 - Rev.
O, 6/72; 1.30 - Rev.
O, 8/72: 1.33 - Rev. 2; 1.37
- Rev. O, 3/73: 1.38 - Rev. 2; 1.39 - Rev. 2; 1.54 - 6/73; 1.58 - Rev. 1; 1.64 - Rev. 2; 1.74 - Rev.
O, 2/74: 1.8 - Rev.
1-R; 1.88 - Rev. 2; 1.94 - Rev. 1; 1.116 - Rev.
0-R, 6/76; 1.123 - Rev. 1; 1.146 - Rev. O,.8/80; 1.144 - Rev. 1 III.
Byron and Braidwood Nuclear Pcwer Stations 1.28 - Rev.1; 1.30 - Rev.
O, 8/72; 1.33 - Rev. 2: 1.37 Rev. O, 3/73; 1.38 - Rev. 2; 1.39 - Rev. 2; 1.54 - 6/73; 1.58 - Rev.
1: 1.64 - Rev. 2; 1.74 - Rev.
O, 2/74; 1.8 Rev. 1-R; 1.88 -
Rev. 2; 1.94 - Rev. 1; 1.116 R, 6/76; 1.123 - Rev. 1; 1.146 Rev.
O, 8/80; 1.144 - Rev. 1 Exceptions or alternatives to this Topical Report for specific plants identified in the Safety Analysis Report or Technical Specification will take precedence over commitments in this Topical Report.
It is also the policy of Commonwealth Edison Company to assure a high degree of functional integrity for its generating facilities so as to achieve high availability of these facilities for the production of electrical power and to maintain overall quality levels which will achieve the foregoing in a safe, effective and economic manner.
The Quality Requirements and Quality Procedures of the Company Quality Assurance Program Manual (see Appendix A for Program Manual Index) as described herein, document the written policies and procedures of the Program and are augmented by other written Depart-ment and Station procedures and instructions.
In the Quality Assurance Department controlled Quality Assurance Department instructive, directive and procedural type documents are used to further explain in specific detail certain department activities as deemed needed.
Such documents may cover items such as training, training program, review of procurement documents, personnel qualification and certification, maintenance and updating of ASME Code information on the computerized Quality Approved Bidders List, etc.
- 42 In addition, Site Quality Assurance Departments may have controlled Site instructions to provide detailed exp~lanations and methodologies for implementing the Quality Requirements and Quality Procedures, and to provide instructions for other site quality activities as necessary.
2-2 Rev. 42 11/21/86 Commonwealth Edison
l The quality assurance programs of Commonwealth Edison Company, Architect Engineers and Nuclear Steam Supply System vendors include the requirements of ASME Section III Article NCA-4000, the quality assurance criteria for nuclear power plants of Appendix B to 10CFR50 " Quality Assurance Criteria for Nuclear Power Plants," and the mandatory requirements of ANSI N45.2, " Quality Assurance Program Requirements for Nuclear Power Plants: and ANSI N18.7, " Standards for Administrative Control for Nuclear Power Plants."
The requirements are implemented by means of detailed quality procedures delineating the specific methodology to be used.
In addition, individual contractor's fabricator's and vendor's Quality Assurance programs will include the applicable portions of the Code, Standards and Appendix B as they affect the total program.
The overall Commonwealth Edison Company quality assurance program, as a minimum, provides for engineering desip control, audit and surveillance of on-site contractors and off-site vendors, surveillance and audit of the performance and quality assurance procedures of the Architect Engineer and CECO Engineering, Purchasing and Construction Groups and for plant operations quality assurance programs covering plant maintenance, repairs, operations, in-service inspections and modifications.
For operating stations, the Corporate Quality Assurance. Program activities also are' covered by written policies, programs, procedures and instructions included in the Station Procedures Manual and other documents.
The Manager of Quality Assurance responsibilities include the establishment and control of the Station Program and preparation and authorization of the Quality Assurance Procedures for operations, audit of station activities and review of the adequacy of the Station Program.
The Station Manager
- 30 provides written procedures and instructions for the Station Procedures Manual and administers the policies, procedures and instructions from the item the Operating License is issued throughout the operating life of the station.
The Quality Assurance Program takes into account the need for special controls to maintain the required quality and the need for verification of quality by inspection and test.
The Station activities affecting quality are accomplished in accordance with the Corporate Quality Assurance Program using appropriate equipment and suitable conditions, and completing prerequisites.
Disputes of a major nature between the Quality Assurance Department and organizations which cannot be resolved will be referred to higher management for resolution.
2-3 Rev. 39 11/20/85 Commonwealth Edison
Achievements of the applicable requirements of the Codes, standards and specifications for materials, structures, equipment and systems will be verified through independent quality control activities.
The control activities will encompass design, procurement specifications, materials, processes, procedures, identifications, testing, nonconform-ance, corrective action, documentation, handling, storage, operating, maintenance, modifications, in-service inspections and repair.
l Commonwealth Edison Company personnel involved in i
Company Quality Assurance activ.ities will be primarily involved in audit and surveillance of quality control and assurance activities performed by various contractors and other Edison personnel.
Inspection, testing and examination activities generally will be performed by outside independent testing service contractors.
To achieve the necessary background and experience for Commonwealth Edison personnel in quality control and i
assurance activities, indoctrination and training programs will be established by the Manager of Quality Assurance or his delegated representative to assure such personnel will have I
adequate knowledge or skill to perform these activities.
These indoctrination and training programs will be an extension Arf their formal' education or work experience.
The training program will consist of, but not be limited to, the following methods as required:
1.
Company Quality Assurance Program Orientation 2.
Formal Training Programs - classroom and hands-on 3.
On-the-job Training - inspections, auditing, testing, etc.
4.
Industry Seminars - concrete, coatings, QA/QC, etc.
I j
5.
Inter-and Intra-Departmental Sessions The orientation sessions covering the Quality Assur-ance Program will include Engineering, Construction, Produc-tion, Quality Assurance, Licensing and Operational Analysis Department personnel.
Various personnel engaged at all levels of site and station activities and general office functions will be included.
These orientation sessions are intended to acquaint personnel with quality assurance / quality control functions and inter-and intra-departmental responsibilities, plus serve as a feedback mechanism to assess and evaluate the Commonwealth Edison Quality Assurance Program.
l 1
I 2-4 I
I Rev. 19 8/7/81 Conunonwealth Edison
Individuals engaged in the quality assurance program (Engineering, Construction, production, Quality Assurance, purchasing and Operational Analysis) activities will be involved in formal training programs utilizing outside agencies and consultants and, as required, l
will include the following subjects:
1.
Quality Assurance / Quality Control principles 2.
Codes and Standards l
3.
Nondestructive Examination (principles and practices) 4.
Special processes 5.
Audits The "On-The-Job" Training program will involve new personnel l
working under the tutelage and direction of experienced and qualified quality assurance personnel.
In addition, these programs will include the following as required:
1.
Site and Off-Site Seminars for selected subjects 2.
Group discussions and problem reviews 3.
Individual training and tutoring 4.
Appropriate company and other educational courses The utilization of Industry Seminars will be made as appropriate for responsibilities and disciplines involved.
Edison personnel engaged in testing activities will be assigned according to their formal education and on-the-job experience.
Additionally, training programs will be developed to indoctrinate and qualify personnel in specific inspection, testing or examination activities in which they will be engaged.
The Material Analysis Manager will be responsible for the development and execution of these programs.
Training will be conducted in a time frame adequate to prepare personnel for their job responsibilities.
When a project or station organization is developed, the Directors of Quality Assurance and Quality *"3 Assurance Superintendents are responsible for reviewing the adequacy of trained and certified personnel and recommending necessary training programs.
Retraining sessions will be scheduled to assure that adequate skills are maintained for qualified and/or certified personnel.
Certification records will be maintained by the Quality Assurance Department as well as the department where in the employe performs his activities.
Qualification and certifications will be maintained in a current status and will be established to meet the applicable requirements of ASME Code including ANSI /ASME NQA-1 and as provided and
- 43 committed herein, ANSI Standard N45.2.6.
2-5 Rev.43 12-22-86 Commonwealth Edison
o
+
^
The training and certification of personnel associated with.
nondestructive examination will be carried out in accordance with the requirements of SNT-TC-1A and the Code.
A Level III certified person will administer this. activity and the program will be under the surveillance of the Directors of Quality Assurance or their delegated representatives.
Likewise, a Letel III certified person i
will administer the concrete containment inspection as applicable under Division 2 of the ASME Code.
Training and certification of personnel associated with concrete containment inspection will be carried out in accordance with Appendix VII of ASME Section III, Division 2.
The period of qualification shall be a minimum of two and a maximum of three years.
Near the end of such a period, employes will be notified that they will require either retraining and requalification and/or decertification to renew their qualification status.
Contractor personnel engaged in inspection, examination and testing activities will be required to be trained, qualified and certified to perform their specific activity in accordance with the
.above requirements.
Such training shall be documented and the record of those receiving training shall include as a minimum the date, duration, subject, the name of the person who performed the training, and the name of the person being trained.
The objectives of the Commonwealth Edison Company Quality Assurance Program >are to: (1) establish with confidence that the design, fabrication, erection and operation phases of its nuclear i
I power generation facilities are performed in a manner consistent with the policies' stated above; (2) provide for documenting, retaining documentation and updating design, fabrication, erection and product quality information necessary for Commonwealth Edison Company operation, maintenance, repair, modification, refueling and i
in-service inspection of the nuclear power facilities: (3) avoid schedule delays and high cost due to poor quality; and (4) achieve I
high plant reliability and availability.
The Quality Assurance Program applies to safety related and ASME Section III activities, items and related consumables plus fire protection, security, emergency plan, meteorology, radioactive material transport packages, and review of environmental qualification of Class 1E Equipment and requirements of the jurisdiction.
The classification of structures, systems and
- 45 components designated as " safety related" are listed in the respective Safety Analysis Reports (SAR) of the Stations.
A copy of the SAR or the listing will be available in the Operations, 2-6 Rev. 45 6/30/87 Commonwealth Edison
Construction, Quality Assurance and Engineering areas, as necessary, for, reference.
Distribution of and revisions to this listing is controlled and approved by the Production Services Department.
The
- 45 requirements in ASME Section III, Article NCA-4000 shall be applied to Section III systems and components including concrete containments.
The 18 Criteria of Appendix B of 10CFR50 will be applied to safety-related systems and components for design, construction, maintenance, refueling, in-service inspection, repair and station modifications.
Criteria 1, 2,
5, 6,
10, 11, 12 and 14 to 18 and Regulatory Guide 1.33 will be applied to operation of safety-related systems and components.
The Manager of Quality Assurance will be responsible for assuring a regular review of adequacy of the Quality Assurance Program.
Periodic written reports will be provided to upper management covering activities and problems involving the requirements of the Quality Assurance. Program.
Also, an overall report will be made annually to upper management for their assessment as to scope, status implementation and effectiveness of the Quality Assurance Program to assure that it is adequate and complies with 10CFR50, Appendix B Criteria.
An independent management audit for upper management shall be conducted on a two year cycle to evaluate the status and adequacy of the Quality Assurance Program.
This annual assessment is preplanned and documented.
Required corrective action is identified and tracked.
The Quality Assurance Programs in the Commonwealth Edison Company Quality Assurance Program Manual and revision thereto are approved and controlled by the Manager of Quality Assurance and may only be revised with his approval.
The Quality Requirements and Quality Procedures shall be revised in concert with addenda to reflect revisions in Section III of the ASME Code.
Such revisions to the Quality Requirements involving ASME Section III shall require acceptance by the Authorized Nuclear Inspection Agency and notification plus evidence of such acceptance to the Authorized Nuclear Inspector prior to issuance.
Concurrently, a copy of the updated Corporate Quality Assurance Manual shall be made available to the Authorized Nuclear Inspector at stations where Code work is being done.
Programmatic changes to the Program are submitted to the NRC Region for acceptance prior to implementation, Organizational changes are submitted within thirty days of the effective date.
Changes which do not reduce commitments must be submitted to NRC at least annually for changes affecting operational stations, and within 90 days of implementation for changes affecting stations under construction.
Changes which reduce commitments must be submitted to and approved by NRC before being implemented.
These requirements also extend to the " principal contractors"--the Architect-Engineer and the Nuclear Steam Supply System vendor for each project.
Initial _ assurance that the current 0.A. program description for each of these contractors has NRC approval, either as a part of the Safety Analysis Report or as a separate Quality Assurance Topical Report applicable to the respective projects, will be established by audits.
These Edison 2-7 Rev. 45 6/30/87 Commonwealth Edison
audits will also assure that each principal contractor has audited its subcontractors, so that changes in those firms' respective programs have not abrogated commitments in the principal
- 2'9 contractors' programs and that such programs continue to meet 10 CFR
- 50 Appendix B requirements.
Quality Assurance Procedures involving engineering, construction, operating and maintenance modification, in-service inspection and Stores activities, and revisions thereto, are signed by the Head of the principally involved department and the responsible Director of Quality Assurance or General Quality Assurance Supervisor (Maintenance) and approved by the Manager of Quality Assurance.
Approval of the Quality Assurance Program Manual Indexes indicates approval of respective changes to the individual pages of the Corporate Quality Assurance Manual.
Sections 2, 5 and 18 of the Quality Procadures provide the procedures for implementing this section of the Quality Requirements.
2-8 I
Rev. 29 4/20/84 Commonwealth Edison
f l-3.
DESIGN CONTROL 3.1 General The fundamental vehicle for design control involves multi-level review and/or evaluation of design documents by individuals or groups other than the original designer or designer's immediate supervisor whose authority and responsibility are identified and controlled by written procedures.
Also, procedures are established to assure that verified computer codes are certified for use and that their use is specified.
The design documents include, but are not limited to, system flow diagrams, design and construction speci-fications, load capacity data sheets, design reports, equipment specifications, process drawings.
Design calculations are also subject to two or more levels of evaluation or review including that performed by the originator plus review and audit by the cognizant
- 45 nuclear stations Engineering, Production Services and Project Engineering Departments, as applicable, for modifications where design work is performed by the Architect Engineer or other vendors or contractors.
Design changes are controlled through document revisions resulting from design change requests and/or design change notices and are reviewed, evaluated and, where applicable., certified l
in the same way as the basic design documents.
These design evaluations or reviews are conducted to written procedures and include consideration of quality standards, quality assurance requirements, materials suitability, process suitability, interface control'and suitability of analytical or testing requirements as appropriate.
Also, design verification, except for l
ASME Code items, may be achieved under a test program by qualification testing of an item under adverse design conditions.
Responsibility for overall design and design control of mechanical, electrical, structural and nuclear related systems and components and compliance of responsibilities to Section III of the ASME Code is assigned to Project Engineering during the initial design and construction and to the Production Services Department
- 45 after plant start-up.
Quality Assurance shall assure that design control requirements are fulfilled through review and audit.
The extent of the design review and evaluation of the original designs and modifications will be determined by the complexity of the system and any safety-related function to be performed by that system.
Design evaluations of modifications will be commensurate with those applied to the original design.
Review and evaluation by the Architect Engineer, the Nuclear Steam Supply System vendor, and/or Project Engineering Department, the cognizant
- 45 nuclear stations Engineering Departments or the Production Services Department will assure that designs and materials will conform to
.the ASME and other applicable codes, standards, regulatory requirements, SAR commitments and appropriate quality standards, as applicable.
3-1 Rev. 45 6/30/87 Commonwealth Edison
~
Project Engineering during initial design and the cognizant
- 45 nuclear stations Engineering and Production Services Department, after plant start-up will review and evaluate the overall design for safety, reliability, inspectability, maintainability and constructability.
The Vice Presidents (Nuclear Stations Operations) are responsible for
- 45 review of designs for operabi'ity, inspectability and maintainability.
The Nuclear Fuel Services Depa.cment will be responsible for either performing reactor core design analyses or for reviewing vendor generated analyses.
The Nuclear Fuel Services Department is also responsible for the design specifications and design reviews for nuclear fuel and in-core components, including when actual work is delegated to other areas.
Coordination of the design review and evaluation effort by Project Engineering, the cognizant nuclear stations Engineering and
- 45 Production Services Department, as applicable, will be, in part, directed toward the identification and control of design interfaces, radiation and environmental requirements, functiors and boundaries, and select. ion and application of materials, parts, equipment appurtenances and components.
Design analysis shall be performed in a planned, controlled and documented manner.
Documentation of the design analysis shall include definition of the objective of the analysis, definition of design inputs and their sources, results of literature searches or other applicable background data, identification of assumptions and indication of those that must be verified as the design proceeds, identification of any computer calculations, including, code or program validation review and approval.
The Project Engineering Department or the cognizant nuclear
- 45 stations Engineering and Production Services Department, as applicable, after plant start-up, with assistance from other organizations, contractors or vendors, shall apply, as applicable, design review and control measures to items such as:
reactor physics; loads and loading combination, transient and accident analysis, compatibility of materials, structural support, accessibility for in-service inspection, maintenance and repair; and delineation of acceptance criteria for inspections and tests.
Project Engineering or the cognizant nuclear stations
- 45 Engineering or Production Services Department, as applicable, after plant start-up, Architect Engineer or Nuclear Steam Supply System Supplier interpret applicable requirements, standards, guides or codes (including classification of ASME Secion Section III items) and use them as a basis for classifying structures, systems and components and establishing boundaries of jurisdiction in each nuclear power plant.
Evidence of design evaluation and reviews and use of alternative calculational methods used to assure verification or l
checking of design adequacy will be documented and retained by Project Engineering Departments, as applicable, and after plant start-up the
- 45 l
nuclear stations Engineering and Production Services Department, or by l
the Nuclear Fuel Services Department for. fuel or in-core related matters.
Errors and deficiencies discovered shall be.
3-2 Rev. 45 6/30/87 Cernoonwealth Edison
_e
' documented and ' appropri ate corrective action shall be taken.
The Projects Engineering Manager prior to plant start-up, and the cognizant NIS
- nuclear stations Engineering Manager or Production Services Manager, as app'licable, after plant start-up for plant modifications, or by the Nuclear Fuel Services Department for fuel or in-core related matters for plant operations, or their respective agent or designee shall certify that a review of the Design Report / Load Capacity Data Sheets has been conducted to assure that all the Design Specification and applicable Code requirements have been considered.
Copies of the certification shall be attached to the copies of the Design Report, design drawings, stress calculations and Design and Construction Specifications and Reports which are made available, as applicable, to the Inspector for review and certification and the enforcement authorities having jurisdiction over the nuclear power plant installation as provided by ASME Section III of the Codes for Classes 1, 2,
3.2 Design Changes Changes to drawings used for construction from the f
corresponding drawing used for stress analysis shall be certified, by the person or organization responsible for the stress analysis calculations, to have been satisfactorily reconciled with those calculations.
Design changes are controlled through document revisions resulting from design change requests and/or design change notices and are reviewed and evaluated in the same way as the basic design documents.
Site and Station design change requests will be reviewed by the Site Quality Assurance Superintendent or designee, Station Quality Assurance Engineer or Inspector, Technical Staff Supervisor, Project Engineering personnel or cognizant nuclear stations Engineering or
- 4 Production Services personnel after plant start-up for plant modifications and/or Architect Engineer, as applicable, and will be approved by Project Engineering Department or the cognizant nuclear
- 45 stations Engineering or Production Services Departments after plant start-up for plant modifications after which the approved change will be incorporated in design documents, approved, released and distributed.
The extent of the evaluation will be determined by the complexity of the change and its safety-related function with respect to the original design.
Coordination of review and evaluation of design changes will be by Project Engineering or the cognizant nuclear stations NIS Engineering or Production Services Departments after plant startup for plant modifications.
The control of documents will be maintained within the system described in Quality Requirement 6.0,
" Document Control."
Plant modifications will be evaluated in accordance with the requirements of 10CFR50.59 and to the requirements of the ASME Boiler and Pressure Vessel Code Section III and will be submitted to the Manager of Nuclear Safety / Superintendent of Off-Site Review and the Production Superintendent.
Also, for Code work the modification will be reviewed with the Authorized Nuclear Inspector who will then stipulate the inspections he intends to make prior to implementation of the modification work.
The Production Superintendent authorizes the modification.
The Technical Staff Supervisor reviews and approves 3-3 Rev. 45 6/30/87 CommonweaHh Edison
the proposed modification and is responsible for verifying that operating procedure changes are accomplished as to station modifica-tions.
The Station Training Supervisor is responsible that required training concerning plant modifications is accomplished for respon-sible plant personnel where the performance of their duties may be affected.
Quality Assurance assures such training is completed.
The Licensing Manager reviews and the Superintendent of Off-Site
- 45 Review reviews and approves proposed modifications to plant systems and components involving a revision to the Technical Specifications or a previously unreviewed safety question.
Evaluation and approval of the substitution of equipment is performed by the Technical Staff Supervisor and either the Production Superintendent, Assistant Superintendent Operating or Assistant Superintendent Maintenance.
The Project Engineering Department, cognizant nuclear stations
- 45 Engineering or Production Services Departments or equipment vendor provide engineering analysis as required by the design specification.
The Project Engineering Department, cognizant nuclear
- 45 stations Engineering or Production Services Departments assigns an organization to verify installation of modifications in accordance with design and quality assurance requirements.
When modifications cannot be completed in accordance with drawings and speci fications, a review for disposition will be requested of the cognizant
- 45 Engineering Department.
The verifying or checking of design features and modifications is done by qualified individuals or organization other than those who prepare the original design or design modification but who may be from the same organization.
The assigned installation department furnishes Project Engineering and, after plant start-up for modifications, the cognizant Engineering Department as-built information to review as
- 45 to correctness and to issue as-built drawings.
Test data required by Project Engineering involving initial l
construction and by the cognizant Engineering Department involving
- 45 modifications to verify the satisfactory installation of components is obtained by organizations designated by them.
After completion of construction, station operating personnel and Quality Control personnel verify the satisfactory final testing of systems required by Project Engineering Department,
- 45 cognizant nuclear stations Engineering or Production Services Departments.
Also, where applicable, before the component or appurtenance is placed in service, copies of the appropriate ASME Data Reports and Certified Design and Construction Reports and l
Design and Construction Specifications are filed at the location of the installation and made available to the Authorized Nuclear i
l Inspector and the State of Illinois enforcement authorities having l
jurisdiction.
Completed Data Report Form N-3, however, shall be filed by Ceco with such enforcement authority having jurisdiction.
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- 4. PROCUREMENT DOCUMENT CONTROL The procurement documents include equipment specifications or specifications for services, each of which are reviewed or eval-uated as described in Section 3 for design and construction, and design and construction for modifications.
Changes to procurement documents are subject to the same review and approval requirements as the original dacuments.
Contract or purchase order documents are reviewed by the NSSS Supplier for NSSS items and by Edison and the Architect Engineer for non-NSSS items to insure that all require-ments have been incorporated specifically or by reference.
Records pertaining to the review and evaluation of procure-ment documents involving initial plant installations and plant modi-fications will include, in whole or in part, minutes of meetings, comment letters, design review records, project quality assurance audits and a copy of the original design document marked with comments or latest revisions.
These records will be kept in vendor k
files and/or applicable Commonwealth Edison Company department files during the Engineering, Construction and Operation phases of the generating station.
The quality assurance and engineering requirements
- 33 including documentation requirements, will be stated, as applicable, in the bid package, contracts and purchase orders for safety-related
- and ASME Code related procurement.
Also, the review for suitability of application of standard "off-the-shelf" commercial or previously approved materials, parts and equipment that are safety-related will be imposed on vendors. Where material, equipment, systems or services require contractors to adhere to ASME Code requirements or have ASME Certi-I ficates of Authorization, these requirements will be contained in the procurement documents.
Quality Assurance Program requir'ements, as well as requirements for subtier procurement, are included as regulatory, code, standard and design requirements.
Similarly, the required methods of identification, preservation and packaging, and methods of controlling conformance to acceptance criteria are covered by these documents.
Quality Assurance Program requirements are included in initial procurement contract and reviewed for acceptability by Quality Assurance to provide for implementation of the approved quality assurance program, vendor evaluation, inspection and test planning, vendor surveillance, witnessing of inspection control points and inspection documentation.
- Also, requirements for vendor documents, such as 4-1 Rev.33 l
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instruction, procedures, drawings, specifications and vendor quality assurance records to be prepared, submitted or made available for review or approval'are included.
In addition, included in the procurement documents are provisions for right-of-access to vendors' i
facilities and work documents for inspection and audit and for vendor reporting and disposition of nonconformance from procurement requirements.
Basic procurement control is by CECO with procurement of major equipment'and items being. purchased by the General Office purchasing Department and procurement of standard type materials and l
items being performed by its satellite purchasing organization at l
Certain sites.
l For procurement initiated by the Project Engineering,
- 45 l
cognizant nuclear stations Engineering or Production Services Department, the cognizant Project Engineer, prior to submittal of the l
Engineering Proposal Request to the Edison General Purchasing Agent, i
prepares a suggested list of prospective bidders for each specification from the applicable Approved Bidders' List and using input from the Architect Engineer and the cognizant Purchasing Department Buyer.
The Bidders lists are' established using such factors as past experience, experience of other utilities, or-specific qualification surveys (either desk or field surveys are used).
For Code work, the desk survey shall be limited to determination that a supplier or contractor is the holder of a valid Certificate of Authorization for the scope of work involved or for 4
determining if a supplier or contractor is potentially qualified.
The final list of prospective bidders as well as the person agreeing to the list are indicated on the Nuclear Proposal Request (NUPR) Form and is approved by the Projects Engineering Manager or the cognizant
- 45 nuclear stations Engineering or Production Services Manager after plant start-up for modifications or designated alternates.
The persons agreeing to the list are key representatives of Project Engineering and Project Construction, or the cognizant nuclear
- 45 stations Engineering or Production Services Manager and'the Project Construction or Station Construction Departments after plant start-up for modifications, Production Department, Purchasing Department and, when requested, the Architect Engineer.
Where bids are obtained from prospective bidders from other than those listed on the Quality Approved Bidders List maintained by'the Quality Assurance Department i
for the Purchasing Department, such bids shall be indicated as trial bids and treated as trial until the bidders are evaluated and approved as acceptable prior to award.
Upon completion of the evaluation of the proposals from approved bidders for either original plant or plant modification items or services, the responsible Project Engineer shall have prepared and, after final review and approval indication by the Quality Assurance Coordinator, shall have transmitted to the Purchasing Department a letter of recommendation and a purchase requisition.
The purchase requisition and/or letter will 4-2 Rev. 45 6/30/87 Commonwealth Edison
i nco r pe, r a te, by reference, those documents such as specifications, drawings, proposals, supplementary proposals, etc., and any conditions of award which form the basis for the evaluation and award.
Edison Purchasing, based on the recommendation letter, its own evaluation and the purchase requisition, shall conduct necessary negotiations and clarifications and make the award to the successful bidder.
Any changes evolving from the procurement activities involving technical or quality assurance matters, either for the original purchase or subsequent change orders, shall.be approved by the originator of the purchase or change order requisition.
The Projects Engineering Manager or the Production Services
- 45 Manager after plant start-up will assign authority for evaluation of the vendor quality assurance program, prior to final award of the contract or purchase order, to the responsible Project Engineer who will request such evaluation be undertaken by the Director of Quality Assurance (Engineering-Construction).
Quality Assurance shall evaluate and approve all such vendor quality assurance programs.
The Quality Assurance Coordinator assigned to the cognizant nuclear stations Engineering, the Production Services and
- 45 Project Engineering Departments is responsible for assuring that the evaluation is carried out and for auditing the manuals of bidders being recommended as acceptable for award as to resolution of comments received by Engineering from Quality Assurance and others i
plus evaluation by Engineering.
As part of the vendor quality assurance program evaluation, the Quality Assurance Coordinator will assure all vendor quality assurance program deficiencies are resolved.
Concurrence by Quality Assurance shall be required.
If the vendor program deficiencies are minor and/or may be corrected by specific procedures for the work to be done, the resolution may follow an award and shall be a condition of the award.
For procurement performed at certain construction sites by the Purchasing Department satellite organization involving safety-and Code-related items, the preparation of the necessary procurement documents is the responsibility of Project Construction.
Procurement by the site Purchasing organization are under the control and management of the General Office Purchasing Department and associated procurement documentation packages are formulated from specifications and drawings issued and approved by Engineering.
The cognizant Field Engineer, or, as applicable, the Project Field Engineering Manager, prepares the suggested list of prospective bidders for each procurement package.from the Quality Approved Bidders' List with direction from the site Purchasing Department Buyers.
The final list of prospective bidders and procurement bid package is approved by the Project Construction Superintendent or Construction Superintendent or designee, or, as applicable, the Project Field Engineering Manager, or their designated alternate.
In addition, such procurement bid packages involving the purchase of ASME Code and 4-3 Rev. 45 6/30/87 Commonwealth Edison
safety-related materials and items are required to be reviewed and approved by the Site Quality Assurance Superintendent, or designated alternate, verifying that the necessary technical and Quality Assurance requirements are included and the proposed bidders are acceptable.
The bids are evaluated by Project Construction and an award recommendation plus a purchase requisition is prepared and trans-mitted to Purchasing via the Site Quality Assurance Superintendent, or designated alternate for final review and approval indication.
Site Purchasing, based on the recommendation of Project Construction, its own evaluation and the purchase requisition conduct necessary negotiations and clarifications and make the award to a bidder on the Quality Approved Bidders' List.
Any changes evolving from the
- 42 procurement activities involving technical or quality assurance matters, either for the original purchase or subsequent change orders, shall be approved by the originator of the purchase or change order requisitions as well as Quality Assurance.
The Vice President (Fuel & Budgets) is responsible for the preparation of nuclear fuel bid documents, for the evaluation of bids received and for the purchase of nuclear fuel.
The Nuclear Fuel Fabrication Inspector provides quality assurance assistance.
The Nuclear Fuel Services Manager, and others as necessary, furnish technical assistance to the Nuclear Fuel Agent during the preparation of bid documents and the evaluation of bids.
When the Assistant Superintendent Maintenance or Technical Staff Supervisor orders spare parts, material and equipment for safety-related items, components and modules to applicable engineering and quality assurance requirements, they specify the quality assurance documentation requirements equivalent to or better than the original installation.
When spare parts, material and equipment are ordered by part number or nomenclature without special engineering requirements being specified, appropriate statements are included in the purchase order to assure they are at least equivalent to the original equipment.
The Quality Control Supervisor shall review and verify that quality assurance, specification, ASME Code and other applicable codes and standards requirements and special requirements are included in the Request for Purchase.
The procurement documents are reviewed and processed by the Production Stores Group.
Coded part numbers are assigned to spare parts.
The Production Stores Staff and the Manager of Quality Assurance, or their designees, review and approve that the quality assurance requirements for documentation of spare parts, welding materials, material and equipment as outlined above are included in the procurement request documents and that the items are ordered from the original equipment supplier or an evaluated and approved alternate supplier.
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1 5.
INSTRUCTIONS, PROCEDURES AND DRAWINGS The quality assurance actions carried out for design, construction, testing, and operation activities will be described.in documented instructions, procedures, drawings, specifications, or checklists.
These documents will assist personnel in assuring that important activities have been performed.
These documents will also reference applicable acceptance criteria which must be satisfied to assure that the quality related activity has been properly carried out.
Activities affecting quality are required by the Edison quality program to be prescribed by documented instructions, proce-dures or drawings.
Procurement documents and the corporate quality assurance programs of Edison, the NSSS Supplier and Architect Engi-neer reflect this requirement.
Each Edison Department involved in safety-related and ASME Section III Code work shall have documented procedures to implement their responsibilities.
Quality Procedures as part of the Commonwealth Edison Company Quality Assurance Manual will be written for design, construction, testing, operations, maintenance and repair activities.
Where appropriate, these procedures will include checklists containing the necessary elements of operation to be observed or measured.
These checklists will be used to the maximum extent practical to document the actions performed.
Generating Station operations, procedures and instructions will be provided by the Station Manager and will be included in the
- 39 Station Procedures Manual in a timely manner consistent with NRC license requirements for administering the policies, procedures and instructions from the time that the Operating License is issued through the life of the Station.
These procedures and instructions include:
Administrative Procedures, Overall Station Procedures, System Operating Instructions, Chemical Control Procedures, Emergency Operating Procedures, Surveillance Procedures, Maintenance Proce-dures, Instrumentation Procedures, and Radiation Control Standards.
Also, a Station Quality Assurance Program for Maintenance, Modifica-tion, In-Service Inspection and Stores Activities will be provided.
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The procedures' include specifications and acceptance criteria as well as vendor documents.
Complex procedures include checklists as part of the procedure and caution notes applicable to specific steps in the procedure are included.
The current revision of the Station ~ Procedures Manual is available in the Station Control Room and is additionally provided to key operating and management personnel.
Maintenance and repairs'to structures and equipment after construction and testing is completed are the responsibility of each Assistant Superintendent Maintenance and are performed in accordance with applicable drawings, procedures, instructions, and/or checklists for Code and safety-related work.
When ASME Code work is involved, these documents shall be submitted to the Authorized Nuclear Inspector for insertion of his hold points.
Drawings, procedures, instructions and/or checklists are used for maintenance and repairs outside the scope of normal station craft maintenance capability.
When procedures and/or checklists are not available for work outside the scope of normal station maintenance craft capability, an outline of the steps to be followed will be prepared to assure proper comple-tion and testing of the maintenance or repair work.
These procedures and/or checklists or outlines are supplemented as necessary by instructions from the personnel responsible for directing the specific maintenance or repair work.
Maintenance, modification and inspection procedures and other quality assurance related documents are reviewed by' Quality Assurance personnel to assure the need for inspection, identification of inspection personnel, and documentation of inspection results plus necessary inspection requirements, methods and acceptance criteria is provided.
Each Station Manager or designee is also responsible for preparation of procedures to assure the safe operation and refueling of the Station in accordance with requirements of the NRC operating
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license.
The Vice presidents (Nuclear Stations Operations) provide
- 45 direction for the preparation of necessary instructions and procedures to accomplish the Station activities in a uniform and systematic manner.
Procedures and instruction supplementing the Quality Procedures of the Quality Assurance Manual will be prepared, es required, reviewed and approved within the individual departments, Generating Stations and Construction Sites responsible for the activities involved as the need arises and their use monitored by Quality Assurance Administration.
Any CECO departmental group l
involved with nuclear plant design, procurement, construction or operation may propose procedures as necessary to meet regulatory, ASME Code or other applicable code requirements.
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The procedures will be independently reviewed and evaluated by other
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involved departments with interface responsibilities and the comments forwarded to the issuing department.
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l 6.
DOCUMENT CONTROL A document control system will be used to assure that documents such as specifications, procedures, instructions, and
- 32 drawings are reviewed for adequacy and approved for release by cuthorized personnel.
Also, this system includes as-built drawings cnd provisions to assure as-built drawings are kept updated, properly maintained, and controlled. Such documents will be distributed to and used at the locations where the prescribed cctivity is performed. Changes to these documents will be handled similarly and will be reviewed and approved by the same organization t
that performed the original review and approval, unless delegated by the. originating organization to another responsible organization.
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Documentation will identify design documents, provide a schedule for completion, define design milestones or other control points, and identify design responsibilities with particluar attention to the definition of organizational interf aces. Design documents will include ASME Code, seismic and other analysis reports, drawings, equipment specifications, work instructions, test procedures, etc., necessary to achieve proper procurement, installation, start-up and operation of systems and components in i
accordance with engineering requirements. Document control will include documents containing requirements for materials, fabrication, special processes, testing, inspection, cleaning, packaging, shipping, storage, maintenance, refueling, operations, and plant modifications, as applicable.
The fundamental control vehicles for documentation relating to Safety Category I systems, structures and components are project distribution lists and periodic document status reports. The Architect Engineer acts as the general distribution agency for project documents (except for internal Edison Quality Assurance Procedures) and carries out the distribution in accordance with a list furnished by Edison for specific types of documents.
Both the Architect Engineer and the NSSS Supplier publish periodic 6-1 Rev. 32 10-05-84
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status reports identifying' nose documents currently-in force.
- 45 L
,Theseireports are distributtoi to all' involved-parties.
Each document recipient is responsible for insuring that only the i
latest; authorized. documents are in use and that void documents are so identified.
Periodic inspections and audits by Quality
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Assurance'are employed as a final check'to assure that the latest
-authorized documents are in use.
Master dis'ribution lists will be used and will designate t
recipients of document' copies.
This listing shall include-document changes, distributions for comments, and/or distribution for use.
Quality Assurance Manual distribution and. revisions, thereto, are controlled'by Quality Assurance using a master distribution list.
r Design document distribution lists applicable to each
. project shall be developed by the Projects Engineering Manager, the cognizant. nuclear. stations Engineering Manager or the
- 45 Production Services Manager and will be coordinated with other CECO personnel as deemed appropriate by the cognizant Project Engineer.
Each list will include an issue date, revision date, and number, project identification, types of design documents, listing of various document recipient positions and the number of copies of each position.
Each' list will be distributed to the t
~ Architect Engineer and to all recipients identified on the list and will be accessible to the-Authorized Inspector for his review
- and use.
.The distribution of documents will be made by the Architect Engineer, or respective Project Engineer, as applicable in accordance with the' distribution list for each project.
Each recipient listed on the distribution list.shall,.
upon receipt of new documents, destroy or segregate and clearly mark all' superseded documents.
Each receiving office'or area l
shall have a controlled method for checking receipt of new or revised documents, and assuring that the latest revised document is in use.
Status reports will be issued periodically by Project Engineering, the cognizant nuclear stations Engineering or
- 45 Production Services Department, as applicable, Architect Engineer and NSSS Supplier to all parties on the distribution list stating the-latest revision of documents to assist recipients in maintaining up-to-date files.
Each document recipient on the distribution list is responsible for insuring that only the latest authorized documents are in use and that void documents are so identified.
The responsible Project Engineering or the cognizant
- 45 l
nuclear-stations Engineering or Production Services Project Engineer shall periodically have the document status reports reviewed to confirm that the latest revised documents are in use.
p Also, verification of compliance to this procedure by a physical l
check of document files, will be periodically performed by CECO Quality Assurance.
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The cognizant Project Engineering Project Engineer has~the
- ~' responsibility to establish document control procedures.and l
methods during design,. construction, preoperational and' start-up testing, and the cognizant-nuclear stations
- 45
-Engineering and Production Services Department Project Engineer for plant modifications, as applicable, to provide that i
i documents are reviewedLfor adequacy and are approved by
. authorized personnel for issuance and use at locations where the prescribed activity will be performed before the' activity is started.
The Station Managet has the responsibility to establish' document control procedures'for operation, refueling, maintenance, and repair. Distribution and revisions of
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. documents at the Station are controlled by Central File in accordance with Station Administrative procedures. The Station
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. Office Supervisor maintains the station files for controlled documents. Superseded documents retained for reference are so marked. The Assistant Superintendent Maintenance assures the latest revisions.of documents for maintenance and repair are in their working files. The Technical Staff. Supervisor will
. incorporate changes to maintenance and operating criteria into station procedures and instructions in a timely manner.
Project Construction, the Station Construction Department or the Nuclear Division Maintenance. Department, whichever has prime responsibility.for new plant construction or modification work, shall be~ responsible for collecting and retaining the inspection and test documentation during' construction and installation of assigned plant modifications and for transferring such documentation to, or within, the Station for review and acceptance and permanent filing.
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V 7.
CONTROL OF PURCHASED MATERIAL, EQUIPMENT AND SERVICES a
- 7.12 General The' control of the quality of purchased material, equipment Land: services is achieved through the evaluation of vendors, surveil-
' lance of their operations and required source inspection, documenta-tion, receiving inspection and retention of quality records.
Both Edison and the NSSS Supplier have direct procurement functions for the Station.
The Architect Engineer offers' recommendations to Edison on vendor selection and reviews vendor efforts as directed by Edison.
Edison will inspect and audit the NSSS Supplier's control of purchased material, equipment and services.
Edison has the respon-sibility for on-site control of Edison and the NSSS Supplier purchased material, equipment and services.
Contractors and suppliers furnishing material, equipment and* services to CECO'for items within the jurisdiction of,this Quality-Assurance Program.will be selected on the basis of demon-strated' capability to provide a product, process or service.in accordance with the design specifications and contract prov.isions.
'The purpose of this Section is to define the quality system elements and related policies which assure the-quality of purchased material, equipment and services through the evaluation of vendors, surveillance of'their operations, required source inspection, docu-mentation, receiving inspection and retention of quality records.
As applicable, the cognizant Project Engineering Project Engineer or.the cognizant' nuclear stations Engineering or Production
- 45 2
Services Department Project Engineer in conjunction with Quality Assurance will require a Quality Assurance ProgrSm in accordance i
with ANSI N45.2 or ASME Boiler and Pressure Code Section III from vendors or contractors consistent with the importance of the procurement to station safety and operation and the requirements of ASME Section III and 10CFR50 Appendix B.
For ASME Code and safety-related procurement, the applicable vendor's Quality Assurance Program shall be identified in the procurement documents and shall require certification to their QA Program accepted by CECO and identification of the QA Program revision and date to which the work was performed or item supplied.
In addition, Edison's procurement documents will provide notification to vendors and contractors that the provisions of 10CFR Part 212 apply.
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programs, procedures and personnel qualification, are the responsi-bility of the specific contractor involved.
Such contractor actions are to be documented and will be subject to audit by CECO.
An evaluation of vendor capability will be required for ASME Section III and safety-related items.
Where valid records of vendor capability and quality performance are not available to CECO, a survey of the supplie::'s f acilities, capabilities and quality assurance system will be made by CECO or its designated represent-ative.
For items requiring ASME Code conformance, vendors must be able to meet ASME Code requirements.
Where material manufacturers or suppliers are qualified by CECO by survey, as provided under ASME Section III, and materials or items are procured directly from such qualified manufacturers or suppliers by another Certificate Holder on the basis of such survey, the qualification documentation shall be provided to the other Certificate Holder prior to its use of the materials or items.
The Project Engineering and the cognizant nuclear stations
- 45 Engineering and Production Services Departments Quality Assurance Coordinator will be responsible for assuring that vendor or contractor Quality Assurance Program evaluations are carried out.
The Quality Assurance Department, for the Purchasing Department, prepares and maintains the computerized Quality Approved Bidders
- List (QABL) for contractors and suppliers of ASME, safety and regulatory related items.
.The Purchasing Department maintains the commercial Approved Bidders List.
Addition of vendors to the Quality Approved Bidders List shall only be made upon approval by Production Services Manager and the
- 45 Manager Quality Assurance, or their designeees, as to meeting technical and quality assurance requirements.
For vendors or contractors to be placed on the Company Quality Approved Bidders' List on the basis of having an approved Quality Assurance Program for ASME, safety or regulatory related items or work, a controlled copy of their approved Quality Assurance Program shall be assigned to the CECO Manager Quality Assurance.
Section 9.0 of this report, " Control of Special Processes,"
establishes the evaluation and assessment of certain process and inspection capabilities of the vendor such as welding, heat treatment, and nondestructive examination.
7.2 Evaluation of Vendors Past performance of a contractor / vendor will be considered during procurement activities by CECO.
Prior to contract or purchase order award, the bidder's capability and quality performance will be reviewed relative to the product, process, or service being procured.
For suppliers of ASME services or items and for Material Suppliers or Manufacturers who do not have a Quality System Certificate (Materials) or an ASME Certificate of Authorization with an appropriate scope a survey of the bidder's facilities prior to award may be required.
Such review will verify ASME Code compliance as applicable.
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7.3 Survnillanco of Vcndor Op3 rations Source surveillance will be carried out through noti-fication points established as a condition of procurement of safety-related or ASME Section III items.
Special consideration will be given for surveillance during manufacture when one of the following is involved:
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a.
Determination of conformance of the item to purchase j
order requirements at any other point would require l
uneconomic disassembly or destructive testing.
b.
Specia? instruments, gauges, or facilities required for inspection or test are more readily available at source and would be uneconomic'to reproduce at the job site.
c.
A receiving inspection would destroy or require replacement of special preservation and packing.
d.
Quality Controls and inspections are integrated into production methods, and inspection at the suppliers plant is necessary to economically verify test reports, inspection records, certifications or other evidence of quality.
Source surveillance by Commonwealth Edison Company or its agents will not nullify the vendor's responsibilities for maintaining a quality control organization delivering items conforming to procure-ment requirements.
Unless otherwise specified, acceptance by Common-wealth Edison Company will be at the nuclear generating station site in accordance with the terms of the contract.
The administration, surveillance and inspection of off-site equipment and material vendors will be the responsibility of the Project Construction or the Station Construction Department, as applicable with final approval of inspection acceptance reports being vested in the Quality Assurance Department.
7.4 Receiving Inspection Materials and articles received from vendors will be inspected upon receipt to assure physical integrity and identity plus documentation compliance with the procurement requirements.
For items not source inspected, specific receipt inspection measures such as material and dimensional checks against approved drawings an6 speci-fications and assurance that ASME Code Data Reports are received will be performed by qualified personnel in accordance with the applicable CECO or contractor QA program and to checklists approved by appro-priate Quality Assurance or Quality Control personnel to verify conformance to procurement requirements.
Where receiving inspection requires the use of calibrated instruments and tools, the identity of such equipment shall be recorded on the applicable receiving inspec-tion documents.
CECO purchases Code items and turns them over to cite Code contractors.
In the case where receipt inspection is 7-3 Rev.32
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assigned to a site contractor, CECO provides them with applicable procurement documents, such as the Purchase Order, Specification, etc., required to assure that the CECO purchased items meet Code requirements and to perform receipt inspection.
Also, for material supplied by non-Certificate holders, the Ceco survey data covering such firms is made available to site Code contractors.
When CECO performs receipt inspection of such purchases or when CECO upgrades stock material for ASME Code use, CECO provides these contractors with the applicable Certified Material Test Reports and/or ' Data Reports plus the Material Receiving Report to provide verification that the purchased items supplied by CECO meet Code requirements.
Documented evidence that material or equipment conforms to procure-ment requirements including, for Code items, indication of their compliance to the specified. quality program must be retained and available at the site prior to use or installation.
Part of this evidence shall be in the form of acceptable documentation such as Certified Material Test Reports, Pressure Test Reports, Certificates of Conformance, etc.. Documentation requirr its will be delineated in the individual equipment specification i e Construction Materials Receiving Coordinator or designee il be responsible for assuring that receiving inspection is completed where Project Construction or the Station Construction Department is responsible I
for the work; receipt acceptance approval will be by Quality Assur-ance or its designated agent.
Where ASME Section III components and
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safety-related materials and equipment are received by the Station
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Stores Supervisor, Station Quality Control will be responsible for receiving inspection and the Quality Assurance Engineer or Inspector for Maintenance shall assure through audit and surveillance that the receiving inspection is complete and traceability is maintained.
ASME Code material transferred from Stores or another CECO Station shall meet the requirements specified for the designated installa-tion.
Nonconforming equipment will be controlled.
7.5 Supplier Audit Vendors of safety-related and/or ASME Section III items will be subjected to survey, audit or surveillance of their quality assurance system by CECO, or its agents, at intervals consistent with the importance to safety, complexity, and the quantity of the product or services being furnished in accordance with approved agenda and checklists to assure that the necessary manufacturing processes are being utilized and that quality controls are being maintained.
7.6 Spare Parts and Replacements Spare parts and replacement items, equipment and components will be purchased to original or better design requirements in accordance with the controls herein.
The applicable quality assur-18 ance requirements will be included in the procurement documents.
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Such spare parts and replacements from vendors will require documentation by item, component, equipment or part number for iden-tification and traceability.
Documentation for material will be in accordance with procurement order requirements.
When the procurement order for ASME Section III components and safety-related spare parts, material, and equipment includes a specification or drawings, docu-mentation will be received from the vendor which verifies conformance with those requirements.
In the case where the original part, item, component or equipment was procured with no specifically identified quality assur-ance program requirements, or was procured from a vendor who no longer can be retained on the nuclear Quality Approved Bidders List
- 42 because of an inadequate Quality Assurance program document, identical spare parts and replacement items, components or equipment may be similarly procured from the original equipment manufacturer (OEM), but care shall be exercised to assure at least equivalent performance:
that is, a joint technical engineering and quality assurance documented evaluation shall be conducted to established requireinents and controls by Technical Staf f or Engineering and by Quality Assurance personnel.
The evaluation shall assure that interfaces, interchangeability, safety, fit and function are not adversely affected or are contrary to applicable regulatory or code requirements.
In the use of procurement of safety-related materials, parts and items that are a manufacturer's standard product (commer-cial grade item), such commercial grade items shall be inspected as part of the receipt inspection function to assure that: (1) damage was not sustained during shipment; (2) the item received was the item ordered (i.e.,
its possesses the required attributes identical, as necessary, to the item specified); and (3) documentation, as applicable to the item, was received and is acceptable plus, after being received, such a commercial grade item shall be tested, where applicable to assure that it will perform its intended function (i.e., by means of bench testing and/or functional testing as required).
A commercial grade item is one that is not subject to design, specification, or testing requirements by the su.pplier that are unique to nuclear power plants; is one that is used in numerous applications other than nuclear power plants; and it is one that can be ordered from the manufacturer / supplier on the basis of specifi'-
cations set forth in the manufacturer's published product descrip-tion (i.e., catalog) or on the basis of its manufacture to national i
I standards.
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When an item is purchased by specifying the manufacturer's catalog part number, when documentation i.s required beyond that l
indicated in the catalog, and when such documentation is not available for items with the same part number obtained from the manufacturer, the item does not meet the definition of a commercial grade item and shall not be treated as a commercial grade item.
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O The Station Stores Supervisor and Station Quality Control Supervisor are responsible for assuring that documentation for spare parts and equipment has been included as part of the ship /or services, ment.
The documentation for the purchased material, equipment, and af ter being reviewed and accepted by the Quality / Control Supervisor will be retained at the Station.
Whenkrequireddocumentationislackingforsafety-related and/or ASME,Section III components or spare parts, the Technical Staff Super!-isor will verify that appropriate documentation is obtained or that suitable inspection and testing is performed to verify conformance to procurement requirements and that such items are treated as nonconformances.
Receipt inspection of spare parts and equipment purchased to ASME Section III and safety-related requirements shall be accepted by the Station Quality Assurance Engineer or Inspector for Maintenance.
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8.
IDENTIFICATION AND CONTROL OF MATERIALS, PARTS AND COMPONENTS 1
A system of. controls will be utilized to prevent the use of nonconforming items or items which have not received the required inspections and. tests. Materials (including consumables),
parts, and components including partially fabricated subassemblies will have their identity marked on the item or on tags and records traceable to the item. Identification assigned to materials, parts and components, including partially fabricated subassemblies, will i
be documented and maintained by the respective vendors, contractors or organizations having responsibility for the items involved throughout fabrication, installation or erection and use of the item and be verified as to being correct prior to release for fabrication, assembling, shipping or installation. The identification system for the-Station will be established.by project Engineering with assistance from the Architect Engineer and Nuclear Steam Supply System vendor as needed, and consists of j
unique numbers assigned to pipes, instruments, valves and equipment. Also, stored spare parts, and equipment will be assigned established Stores Items Numbers by the production Stores Group. Quality Assurance will assure such identification and traceability is provided.
Assigned identification of materials, parts and components will be unique to the item. Identification will be on the item where practicable, and/or on records traceable to the item.
prior to dividing material or cutting the markings, the marks or coded marking shall be transferred to the parts to be cut
- 42 and such identification shall be independently verified.
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During fabrication, installation, erection and use of items, identification will be maintained traceable to the documentation of sub-components and/or materials when specified.
1 Engineering review will establish that stamps, tags, or labels affixing identification to an item will not affect the properties or otherwise cause deterioration of the item and that stamps, tags and labels shall be made of material that will assure identification is not lost. The identification systems used by Commonwealth Edison Company, its contractors and major vendors for a nuclear generating station will be integrated to the extent necessary for uniformity.
The identity of items, components, equipment and systems i
generally will be applied during the design phase.
The procurement of items and components will use this identity and it will be maintained during fabrication j
8-1 Rev. 42 11/21/86 Commonwealth Edison
performed by vendors.
The receiving inspection, erection, repair and maintenance records of engineered items and components which are filed at the construction site or Station will be traceable to the engineering identity.
Items and components which have not been subjected to required inspection and tests prior to receipt will be tagged or marked and controlled to preclude usage.
- Also, nonconforming items will be identified and controlled to preclude usage.
Stored replacement a. pare parts and equipment will be similarly identified by Stores Item Numbers during purchase, storage, and installation to assure requim d traceability to records and documents and to prwent their incorrect use.
Part numbers are assigned by the~ Production ~
Stores Group.
The Station Stores Supervisor maintains parts, 10 material, and equipment in storage traceable to quality assurance documents.
l 8-2 Rev. 10 9/28/79 Commonwealth Edison
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9.
CONTROL OF SPECIAL PROCESSES For some processes, the required level of quality defined in ASME Code and other applicable codes, stardards and specifications cannot be assured by inspection of the item alone.. For these processes, quality assurance is obtained through reliance on personnel qualification and procedural control in force as appropriate for the processes being employed for a specific task in connection with plant contract work, maintenance, repairs and modifications.
The application of these controls is assured through audit / surveil-lance activities by CECO or its agent at vendor plants and/or at.the site and by Edison Quality Assurance at the operating stations.
The Edison Site Quality Assurance Superintendent or 11 5 designee and the Quality Assurance Engineer or Inspector at the i
operatig station is responsible for assuring that records of qualified personnel are maintained by the contractor for work performed for Edison.
These special and construction processes include welding, heat treating, concrete placement, coating, plating, material cleaning and bonding, chemical processes, certain nondestructive testing processes and such additional processes that may be identified in the contract, purchase order or maintenance or modification procedure, as the result of ASME Section III, Division 1 and Division 2 for concrete containment requirements and/or design review.
Procedures for the control of special processes will be maintained for components within the primary system pressure boundary and other safety-related items and ASME Section III designated components.
These procedures will be in accordance with ASME and other applicable codes and speci-fications.
When there is a specific reason to question whether the special process procedure or qualifications of personnel requirements are being met, the Authorized Nuclear Inspector may require requalification.
Process control procedures will be used as required by specifications, Code or standards, as applicable.
Supple-mental procedures will be prepared as necessary to provide detailed performance and methods for control of special processes and concrete placements for concrete containments.
Process control procedures will specify the preparatory 9-1 Rev. 15 1/2/81 Commonwealth Edison
t s
stcps, processing d tails, conditions to be maintained during the l
steps of process, inspection and test requirements and records
{
requirements. Process control procedures of contractors and vendors will be submitted to Commonwealth Edison Company for review and 1
evaluation in accordance with documented Commonwealth Edison Company
)
procedures.
Process control procedures will specify the methods of verifying the adequacy of processing materials, solutions, and equipment, including definitions of their associated control i
parameters.
When the process is conducted in special environments, such as in vacuum or inert gases, the process control procedures i
will specify the requirements and methods for maintaining such environments.
The control and approval of sub-vendor Quality Assurance and Quality Control procedures are the responsibility of the l
specific vendor involved (included NSSS vendor).
Control procedures for nondestructive examination processes such as radiography, ultrasonic testing, liquid penetrant
{
inspection, and magnetic particle inspection, will be used by j
Commonwealth Edison Company and their contractors and vendors to
)
assure that the results provide accurate, uniform and reproducible indications of actual quality.
j Commonwealth Edison Company and contractor and vendor l
personnel responsible for the performance and verification of special processes and the. inspection of concrete placement involving concrete containments and other inspection and test activities will be certified as required by specifications, ASME Code or other applicable codes and standards. Certification of perscnnel for such processes and concrete inspection and other inspection and test
- 32 activities will include necessary training followed by an examination of each individual.
The period of validity for certifications shall be specified, and each individual shall be decertified at the end of such a period by retesting or by demonstration of satisfactory performance.
Personnel failing retest shall be removed from operations pending requalification.
Personnel j
who have not performed inspection, examination and test activities in the qualified area for a period of one year shall be re-evaluated to re-establish required capability.
Training, testing, and qualification of personnel shall be in accordance with criteria described in ASME Code, standards and specifications.
Process control records will provide objective evidence j
that special processes were performed in compliance with approved process control procedures by qualified personnel.
Process records j
will specify the inspection and test data to be verified.
Results of nondestructive examinations will be recorded in accordance with applicable specifications, codes and standards.
These records will be retained by Commonwealth Edison Company or when the work is contracted, they will be retained by the vendor and then supplied to Commonwealth Edison Company as required by procurement documents.
l 9-2 Rev. 32 10/05/84 Commonwealth Edison i
During construction and assigned plant modifications, the responsibility for implementation of special and construction process procedures and qualification of such procedures and of personnel performing the work is that of Project Construction or Station Construction,.as applicable, and shall be under the surveillance and audit control of the Site Quality Assurance Superintendent at-the construction site and Station Quality Assurance Superintendent at the operating station.
During station operation, the Assistant Superintendent Maintenance assembles and maintains the qualified procedures used-by station maintenance personnel or contractor. For ASME Code work, nondestructive examination procedures shall be approved by a CECO Level III person and the heat treating and welding procedures shall be reviewed and approved by Production Services Manager and the Manager Quality Assurance.. persons *45 performing such special processes shall be qualified in accordance with the requirements of the Code and standards.
Implementation of procedures during operations is by the Assistant Superintendent Maintenance or:
designee and, for the most part, cover those procedures included in the Special Process Procedures Manual. Completion of inspection, tests,
'dudits and documentation is verified by the Station Quality Control Group and assured by the Station Quality Assurance Engineer or Inspector for Maintenance.
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Commonwealth Edison
- 10. INSPECTION Inspection Programs will be established to provide assurance that the quality control surveillance, inspections and tests defined in the applicable equipment and concrete containment specifications are performed.
Quality Assurance inspection and testing will be conducted at vendor facilities, at the Site during construction, and at the Station during operation, maintenance and modification activities to verify conformance to applicable drawings, instructions, and procedures as necessary to verify quality.
In addition, in-service inspection will be carried out in conformance with requirements of ASME Section XI.
Inspection and test control points, to be witnessed by the Authorized Nuclear Inspector, and Commonwealth Edison Company or its representative, will be established as required to assure quality of items and effectiveness of the inspection programs.
Individuals performing inspections shall have the necessary qualifications and shall be independent of the individual directly responsible for performing the specific activity.
Quality Assurance personnel will periodically review the inspection activities to establish their capability and to assure that required qualifications are met and kept current.
Inspection personnel shall be qualified in accordance with the requirements of the ASME Code or ANSI N45.2.6, l
as applicable, for Code and safety-related inspection activities.
l Equipment and material contracts with off-site vendors are administered by Project Construction during plant construction and by the Station Construction Department, thereafter.
- Thus, under the inspection programs administered and conducted by Project Construction and Station Construction Department of off-site vendors for purchased materials, an inspection and test plan will be prepared for purchased Code and safety-related procurement based on specified engineering requirements and the specific fabrication techniques and sequences to be used for such procurement.
Approval of such a plan and approval as to the quality requirements being satisfied is the responsibility of the Site Quality Assurance Superintendent and the Station Quality Assurance Superintendent, or designees, as applicable.
- 42 Inspections may take the form of source inspection, receiving inspection or both, depending on the nature, importance and quantity of the item (s) procured.
Inspections will be performed to written procedures or checklists for inspections approved by Quality Assurance.
Procurement documents shall contain provisions for Edison's right-of-access to vendors' and subvendors' facilities and records for source inspection and audit.
The NSSS Supplier will conduct inspections on items procured under the NSSS cc.mu act.
This does not preclude Edison j
inspections of those same items.
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The I:dison Site Quality Assurance Superintendent or designee will l
l assure that surveillance of contractors' activities is performed in accordance with Quality Assurance approved surveillance procedures, and inspection and audit program and checklists.
Edison establishes l
inspection notification points, including certain points designated by Quality Assurance which cannot be waived by the Site Construction
.I Superintendent or project Engineer without approval of Quality Assurance, which will be witnessed by Edison, or its designated agent. The applicable Edison Site Quality Assurance Superintendent or Station Quality Assurance. Superintendent, or designees will assure that required *42 inspection of purchased items as required and determined by Engineering is carried out, that inspection procedures, instructions or checklists specify the necessary' measuring and test equipment including accuracy i
requirements, that contractor test procedures approved by Edison or the Architect Engineer are judiciously implemented and that procurement requirements are being fulfilled. In preparing an inspection notification point witnessing plan, Edison will take into account applicable codes, standards, specifications and contractor quality control procedures. The plan for each inspection will also identify, for example, the parameters to be checked, accept / reject criteria, equipment needed for the inspection or contractor documentation to be reviewed. Inspections associated with normal operation of the plant such as routine maintenance, surveillance and tests on safety-related mechanical and electrical equipment and systems is followed by functional or operational tests conducted in accordance with approved procedures by operations personnel. Acceptance criterion must be met before the equipment is declared operational.
1 Inspection and test plans shall be prepared by respective contractors, vendors or organizations having responsibility for the
)
item (s) involved, either as a separate document identified with the parts, components or assemblies; or as an integral part of work instruction and procedure documents. Inspection and test plans shall consist of a flow chart, diagram or narrative description of the sequence of procurement, fabrication, processing, assembly, inspection and test activities and shall specify the inspection points.
The criteria for selection of testing methods will be based on those needed to verify design requirements. Sampling inspection methods may be used when tests are destructive or when the quality records and the inherent inspection characteristics of the item indicate that a reduction in inspection or t'esting can be achieved without jeopardizing the assurance of quality.
Sampling methods for Code items require prior approval of CECO or i
its representative as required by contract and approval shall be based on the use of a nationally recognized sampling method.
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The importance, relative complexity, point of acceptance, and quantity of. items will determine whether manufactured items will be inspected at source or upon receipt. Source inspection is to be utilized
. under the same criteria as source surveillance with the additional requirement that there are control points in the contractor / supplier's manufacturing plan which must be identified for notification to CECO or its agents prior to proceeding with manufacture. Items which have been inspected at source will also require _ sufficient receiving inspection to assure physical integrity and identity plus documentation compliance with the procurement requirements.
Certification of chemical and physical properties and laboratory verification of materials will be required when indicated by applicable codes and standards, by design requirements, or as stated in the j
In-process and final inspections and tests will be used to assure conformance to design requirements for fabrication and construction work.
Written procedures or checklists will be used to specify and verify final inspections and tests, Changes to approved procedures will be documented and will be reviewed and approved by personnel with equivalent engineering and
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quality assurance technical competence as the personnel that established the procedure. Final Test procedures and associated changes involved in ASME Section III, Division 1 and Division 2, Class CC, when CECO has overall responsibility, will be submitted to the Authorized Nuclear Inspector for review and concurrence.
Inspection and test records will provide objective evidence that inspections and tests were performed in compliance with instructions and procedures to verify design and Code requirements. Inspection and test results will be recorded to show-conformance with acceptance criteria and/or record and identify the cause of rejected items. Also, inspection and test records will identify the inspector or recorder.
Data and results will be distributed to personnel who require the information for review and/or retention.
Nonconforming items will be identified, segregated, and disposed of and appropriate corrective action (s) will be initiated.
Rework, repair, or replacement performed after completion of inspection or tests will require reinspection and retest to the extent
- 33 necessary to establish acceptability to the original criteria.
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11.
TEST CONTROL Test programs will be established to assure that-I design and performance criteria have been satisfied.
The test programs will include, as appropriate, procedures to evaluate structures, systems, subsystems and components.
The program will include, as applicable, proof tests prior to installation, construction, reoperation, and start-up
- tests as required for a new plant and operational tests, as well as those tests applicable involving and following plant maintenance or modifications.
Appropriate testing is performed and documented by trained or appropriately qualified personnel to assure
- that applicable ASME Code and safety-related structures, systems and components perform satisfactorily in service.
The test program will consist essentially of four testing stages:
Vendor Testing.
Consists of source testing 15 such as hydrostatic testing, seismic testing, performance testing and environmental testing as appropriate and as reflected in the npecific procurement documents for a given item or items.
Approved written procedures will be required for these tests and the test results will be evaluated.
For items procured under the NSSS contract, the NSSS vendor will act as Edison's agent in this regard subject to inspection and audit by Edison or its designated agent.
For non-NSSS items, the Architect Engineer may participate with Edison Engineering or act as Edison's agent in ppproving test procedures and data.
Construction Testing:
Consists of on-site component testing such as hydrostatic testing, pressure proof testing, pump and valve testing, actuation to verify proper installation and electrical continuity verification.
Written procedures or checklists will be employed and the status l
11-1 Rev. 15 1/2/81 Commonwealth Edison
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of equipment both before and after testing will be documented.
The varicus on-site service contractors will generally perform these tests.
Control and management of the tests is the responsibility of the Project or Construction Department's project / Field Engineer, as applicable.
The Site Quality
- 41 Assurance Superintendent or designee will be responsible for determining and assuring that proper calibrated inspection equipment is utilized, that equipment'is properly released for testing, inspections and tests are done under suitable environmental conditions, that data documentation is in compliance with procedures and that retention control of test data documentation is adequate. The Authorized Nuclear Inspector shall1 be notified of all ASME Code hydrostatic or pneumatic tests prior to conducting them to to permit his witnessing of such tests.
Preoperational Testing:
Consists of system performance tests performed prior to (or in some cases, after) core loading and are performed on completed or essentially completed systems.
Preoperational' tests which are performed on critical Safety Category I equipment, are controlled by approved written procedures and are. evaluated in accordance with the Edison Quality-Assurance Program. The Site Quality Assurance Superintendent or designee will perform a final review of all Equipment releases to assure that all comments and exceptions have been resolved and will sign the release for equipment turnover to. operations. Also, Quality Assurance shall monitor such tests to assure they are performed properly and evaluated by the correct people.
Preoperational Testing is performed by the contractor or Edison station operating personnel.
Start-Up Testing:
Consists of those single and multi-system tests beginning with fuel loading which are intended to demonstrate overall plant performance. These tests include the low-power physics tests and the power escalation testing program. Those tests essential to demonstration of safe operation will be' conducted under a program having the same requirements as the formal preoperational tests.
j Nonsafety-related testing, if performed, will be controlled in a manner similar to component demonstration tests.
Start-up tests will be performed by station operating personnel.
11-2 Rev. 41 8/12/86 Commonwealth Edison
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The start-up testing program commences at fuel loading and' proceeds through several power level plateaus through 100%
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power.
As applicable, the projects Engineering Manager or
- 45 l
L the cognizant nuclear-stations Engineering Manager of the Production Services' Manager of their designee (s) approves the start-up test procedures and data.
Start-up testing of systems is assigned to Technical Staff Engineers. They assure that the construction and preoperational tests are complete and that the start-up test. procedures incorporate.the requirements and acceptance criteria' contained in the applicable design documents. Th'e start-up procedures review assures the' prerequisites have been met, adequate test instrumentation is available for use and the tests will be performed under suitable conditions.
After start-up test results are evaluated and accepted by the cognizant Projects Engineering Manager or the cognizant
- 45 nuclear stations Engineering Manager or the Production Services Manager or their designee (s), as applicable, an acceptance statement is issued by responsible Manager or designee. The Site Quality Assurance Superintendent or designee assures that start-up test requirements ~are fulfilled.
The Production Superintendent indicates concurrence and satisfactory completion of start-up tests.
Modification testing requirements are specified by the cognizant Commonwealth Edison Company engineering department and/or Technical Staff personnel and reviewed and accepted by Station Quality Control. Results from the. tests are reviewed and approved by the Technical-Staff Supervisor and by the Assistant Superintendent Operating, or designee.
Test results which do not agree with requirements shall be forwarded to the cognizant Engineering Department for acceptance.
- 45 Required testing before equipment is returned to service is defined in the instrument and equipment maintenance work procedures. The acceptance of functional tests is assigned by the Assistant Superintendent Operatir.g to the station operation or Technical Staff personnel. The t.ssistant Superintendent Maintenance or Quality Control Supervisor review and accept the maintenance records for completeness. The Station Quality Assurance Superintendent assures that all testing and documentation requirements are fulfilled.
11-3 Rev. 45 6/30/87 I
Commonwealth Edison
Tests during operations other than routine surveillance tests are performed and documented as prescribed by the Technical Staff and Assistant Superintendent Operating to verify continued
- 39 satisfactory performance of safety-related structures, systems and components.
The test results are evaluated by the Technical Staff and station quality control personnel.
Written test procedures will be developed to demonstrate l
design and performance characteristics as specified in design and operating requirements. The procedures will include provisions for hold points to be established and for assuring that prerequisites have been completed and state the data to be obtained and requirements and acceptance limits to be fulfilled. Specifically, the Authorized Nuclear Inspector shall have the opportunity to establish his hold points prior to the approval of the test procedures written for the tests required by the ASME Boiler and Pressure Vessel Code Section III or XI. The tests will be performed under the appropriate conditions using adequate, appropriate, approved and calibrated test equipment.
Data will be examined frequently as each test proceeds, and out-of-tolerance conditions will be recorded and described in adequate detail to permit post-test analysis.
Test results will be evaluated following each test to assure conformance with design and performance requirements. The evaluation will determine the following:
1.
That the appropriate test procedure was used.
2.
That the data displays the adequacy of the equipment to meet the specified requirements.
3.
That nonconforming or incident conditions, if applicable, are reported and corrected.
Test records will include data sheets completed during the tests and a list of those instruments used for calibrating equipment. The data sheets will have provisions for identifying the person responsible for conducting the test and the date or period when the test was performed.
The original test records shall be reviewed for completeness, identified, and indexed to establish them as a part of a permanent record to be retained.
11-4 Rev. 39 11/02/85 Commonwealth Edison
12.0 CONTROL OF MEASURING AND TEST EQUIPMENT 12.1 GENERAL Measuring and test equipment which is used to determine the acceptability of materials, parts, components, fabricated items,~and completed construction assemblies, and to perform the pre-operational testing and to ascertain the proper indications in the operation of generating station equipment will be periodically calibrated or adjusted and properly handled and stored to assure that accuracy is maintained within necessary limits in order to verify design requirements.
Such measuring and test equipment will be calibrated against standards in accordance with approved pro.cedures having tolerance not greater than one-fourth the tolerance of the measuring and test equipment being calibrated.
In situations where it is impractical to comply with the above, a j
standard of greater than one-fourth the tolerance but equal to or closer than the tolerance of the measurement and test equipment described will be used with proper documentation and approval.
Inspection, measuring and test equipment will be adjusted and calibrated using documented procedures at scheduled intervals against certified standards having known valid relationships to recognized standards.
Such procedures will provide criteria for determining the accuracy requirements of test equipment and criteria for determining when a test is required or how and when testing activities are performed.
Calibration intervals for items will be based upon the type of equipment, accuracy, use and other conditions affecting measurement control.
Commonwealth Edison or its contractors and vendors, may provide calibrations of measuring and test equipment, or use the
~
services of an approved calibration laboratory.
In either case, approved standard procedures will be used for calibration work.
Ctandards will be maintained and used in an environment with temperature, humidity and cleanliness controls compatible with maintaining accuracy.and operating characteristics of the standards.
History records for measuring and test equipment will be used to indicate calibration status, condition, correction to be applied and repair events.
As a minimum, these records shall include, the equipment and Standard serial numbers, date of last calibration, due date of next calibration, calibration data and
- 42 results as-found condition, repairs performed and, out of tolerance notification as required.
12-1 Rev. 42 11/21/86 Commonwealth Edison i
Traceability records will be maintained in the System O?erational Analysis Department for nonradioactive certified I
. standards to show that calibrations are traceable to recognized national standards. Also,. records will be maintained in the
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Operational Analysis Department for company standards as well as j
calibration records for inspection, measuring and test equipment.
If no national standards exist, the basis for calibration will be documented.
Further, the construction site or Station shall maintain necessary calibration records and status and identification tagging.
Reputable commercial calibration laboratories shall be employed when needed and their standards will be traceable to recognized national standards.
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12.2 EQUIPMENT CONTROL j
The basic control measures employed'for measuring and test equipment consists of periodic calibration using appropriate standards and documented procedures.
The control includes documentation and recording of calibrations, tagging or equivalent methods to show calibration status, and, when necessary, written procedures for the use of equipment.
For each piece of test and measurement equipment, the date of last calibration, the calibration data, and the due date of next calibration shall accompany the piece of equipment at the time of calibration and shall remain with the equipment until the next calibration.
These items shall be identified by use of tags or stickers. Inspection and testing equipment utilized for acceptance measurements shall be identified by serial number as part of the documented inspection and testing data.
When measuring and test equipment is found to be out of calibration, an evaluation shall be made and documented of the-validity of previous inspection or test results and of the acceptability of items previously inspected or tested.
The Station Maintenance Department (or cognizant Construction Engineer during construction) will be notified by an out of calibration report to
- 42 l
the. user for corrective action and to QA for correction action f
verification.
Written procedures appropriate to the item (s) of measuring and test equipment involved will be used to specify preoperations checks, environmental requirements, step-wise instructions for use, and instructions for shut-down and layaway.
Suppliers and contractors to Commonwealth Edison Company are required to have and employ similiar appropriate control measures which Commonwealth Edison Company will assure through surveillance, audit and approval of contractor procedures.
l The Operational Analysis Department will be responsible for l
calibration and maintenance of Commonwealth Edison Company measuring i
and test equipment. Assistance in this activity will be obtained
)
from vendors or laboratories who have the necessary capabilities.
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12-2 Rev. 42 l
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l Commonwealth Edison
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The Master Instrument Mechanic is responsible for the calibration and control of station instrumentation and for the accuracy of tools, gauges, instruments and other devices used in measuring and testing such instrumentation as well as documentation of such calibration and control.
The Assistant Superintendent Maintenance similarly is responsible for tne calibration and control
- 39 of tools, gauges and instruments used in maintenance activities. To maintain accuracy within necessary limits, the measuring and test equipment used in activities affecting quality is periodically calibrated and adjusted in accordance with Quality Procedures for test equipment and system instrumentation.
All pressure test gauges used in ASME pressure testing shall be calibrated against a standard dead weight tester or a calibrated master gauge prior to each test or series of tests.
Charpy V Notch testing machines shall be calibrated at least once each year in accordance with ASTM-E-23-72 and employing standard specimens obtained from the U.S. Army Materials and Mechanics Research Center. The associated temperature instruments shall be calibrated at least once in three month intervals or, when
. utilized with longer periods between use, such calibrations may be
. performed prior to being used.
The Master Instrument Mechanic and Assistant Superintendent Maintenance develop a master list of equipment to be calibrated. For
- 39 each piece of equipment on the list, the Master Instruraent Mechanic, Assistant Superintendent Maintenance or Operational Analysis
- 39 Department or their contractors maintains the primary standards used in the calibration of the equipment; calibrates the equipment; maintains records traceable to the instruments, tools and gauges showing the date of the last calibration, the calibration data and the due date of the next calibration; and provides records of calibration data for the Station files.
The Master Instrument Mechanic performs the instrument surveillance testing as required by the Technical Specifications to assure the accuracy of station process instrumentation in accordance with Instrumentation Procedures.
Instrumentation Procedures and documentation are established per the Instrumentation Procedures of the Station Procedures Manual.
12-3 Rev. 39 11/20/85 Commonwealth Edison
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13.0 HANDLING, STORAGE AND SHIPPING
. Written procedures and instructions for handling,
- 26 preservation, storage and shipping will be used to specify special protective conditions neccessary to prevent' damage or
. deterioration'of materials and equipment.
The requirements needed to provide adequate receipt of material and equipment are
- established by Engineering in the equipment specifications or vendor instructions.
Speci'al handling procedures and instructions will be
- 26 Lprovided for items that are susceptible to handling damage.
lDuring fabrication, processing, construction, modifications, or installation, special carts, cranes, boxes, containers, and transportation vehicles will be utilized as necessary to prevent
- damage due to handling.- Construction, installation and test sites will be'provided copies of special: handling instructions as appropriate.
Operators'of special handling and lifting equipment. *
- chall be experienced or-trained in their use.
Such equipment and *26 special handling tools'shall~be inspected and tested.in accordance *
-with procedures and at specified time intervals.
Procedures and instructions for preservation will be
- 26 provided for items subject tx) deterioration or damage through exposure to air, moisture, or other environments during fabrication, processing, assembly, and interim storage periods.
. Items _will be cleaned and preserved by such methods as required to preclude deterioration. Items subject to damage will be packaged in a manner and withisuch materials as required to prevent damage.
When maintenance of specific' internal or external environments are necessary, these will be included in special packaging instructions.
i For items which are required to be stored for long periods of' time or require special protection, storage instructions will specify special protective environments necessary to prevent deterioration and damage.
Procedures and instructions will provide for adequate *26 safety, maintenance of preservation, special protective environments such as inert gas atomsphere and humidity and temperature control, periodic inspection, and periodic accountability.
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13-1 Rev. 26 12/10/83 i
Commonwealth Edison I
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'dendor's Quality Program will include shipping procedures which vill provide for inspection and control of items leaving the supplier's plant to assure the following:
a.
Items have been subjected to and have satisfactorily passed applicable inspections and tests.
b.
Items are-complote and assembled as required.
c.
Items have been preserved and packaged in accordance with applicable procedures and contract requirements.
d.
Packaged items have been identified and marked in accordance j
with applicable procedures and specifications.
e.
In the absence of packing and marking requirements in the contract or subcontract, the packing and marking of items will be such as to be readily identifiable at destination.
f.
Items shipped from a vendor will be accompanied with necessary 3
shipping documents including special handling and storage instructions, if required.
For Code items that are to be turned over by CECO to site contractors or shipped to other users, such items will be either
- 26 turned over to the contractor upon delivery or turned over or shipped
- from the CECO site storage, with documentation required by the contractor or other user.
This activity shall be performed in
- 26 accordance with approved procedures or instructions.
During construction, the Project Construction and Quality Assurance groups shall provide surveillance and audit of on-site receipt handling and storage of material and equipment.
Project Construction, however, shall have prime responsibility for this activity.
The primary documents for controlling, handling, storage and shipping of items are approved written instructions or procedures which delineate acceptable techniques and necessary qualifications and precautions.
A storage plan is established by Project Construction at each site utilizing 'information provided by the -
Project Engineering Project Engineer and Contractor. After licensing, the assigned Station Construction Department Engineer, when performing plant modifications, will provide surveillance of handling, storage and receipt of material and equipment for plant modification.
Inspections and audits are conducted to verify compliance with the plan or procedures and other requirements by the Edison Quality Assurance.
The Project Construction or Station Construction Department Field Engineer, as applicable, provides surveillance of the field activities of assigned contractors to verify the application of such instructions to the equipment.
When required by the terms of the purchase order, the supplier providing the spare parts, material and equipment for the Station, also provides instructions for the special handling, storage, shipping, cleaning or preservation of such items to prevent damage or deterioration.
Items received at the stations will be inspected for evidence of damage during transit. Storage 13-2 Rev. 26 12/10/83 Commonwealth Edison
areas and facilities are provided to assure protection of stored items.
The Station Stores Supervisor controls such special handling and storage of station and other assigned spare parts, material and equipment in accordance with supplier instructions.
Also, storage of chemicals, reagents (including control of shelf-life), lubricants, and other 11 consumable materials is controlled.
Procedures and instruc-tions to protect nuclear fuel are provided as part of the Station Procedures Manual for use by the Fuel Handling Foreman and the Nuclear MaterialseCustodian.
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13-3 Rev. 11 12/21/79 Commonwealth Edison i
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- 14. INSPECTION, TEST AND OPERATING STATUS
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The measures used to indicate the status involve two phases. The first phase is pre-receipt controls used to insure that all requisite tests and inspections scheduled to be performed at a vendor's shop have been made. The controls applied to this phase consist of vendor progress reports, inspection notification points and quality release documents which accompany the item to the site or station. The second phase consists of on-site controls and identification of status on-site or at the station. These controls consist of documented receipt inspections and item tagging to indicate nonconforming status during construction and operation phases of the nuclear generating station.
This system of control will provide for the identification of items which have j
satisfactorily met required inspections and tests prior to arrival at.the construction site. This system will also provide for indicating the quality or operating status during construction and j
plant operations. Marking, tags, labels, forms, log books or other j
suitable means are used to identify the operating status of parts j
and equipment to preclude inadvertent bypassing of the inspections and tests required prior to their use.
The operation status of station equipment is under control of the Shift Engineer. The inspection and testing status is under control of the cognizant Organization Head (i.e.,
maintenance - Assistant Superintendent Maintenance; stores -
- 42 Storekeeper; etc.). The Equipment Outage Book is maintained by the Shift Engineer to identify the operating status of station i
equipment taken out-of-service. A Quality Procedure describes the use of the Equipment Outage Book to assure correct identification i
of equipment removed from service.
Material Receiving and Inspection report forms will be used to indicate the physical condition and conformance to 1
specification.
Inspection and test status during construction will be indicated by logs and test 14-1 j
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records. Nonconforming material and equipment will be identified through the use of a Qtrality Assurance " Hold" tag.
Unacceptable
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material will be identified v4.th a Quality Assurance " Reject" tag.
Such " Hold" and " Reject" tags shall only be removed at the direction of Quality Assurance personnel.
Operating out-of-service status is controlled by Edison " Hold" and "Out-Of-Service" cards depending on 3
the designated internal jurisdiction of the item. The methods of control are provided through Construction and Station Operating procedures which describe the use of forms, tags and logging methods.
i 14-2 Rev. 26 06/19/85 Commonwealth Edison
i 15.
NONCONFORMING MATERIALS, PARTS OR COMPONENTS AND OPERATIONS Items or conditions involving construction, maintenance
- 26 and modifications which are found nonconforming to the engineering requirements or specifications, drawings and instructions for modifications or workmanship standards or which are lacking required documentation upon receipt will be controlled to prevent their inadvertent use or installation.
Nonconforming items are identified, documented and segregated for disposition.
Technical evaluation will be performed by qualified personnel to determine whether a nonconforming item may be accepted "as-is" repaired to an acceptable condition, or whether the item must be rejected.
Items may be reworked to conform with design and/or specification requirements without technical evaluation.
When items are accepted "as-is," technical evaluation will be performed to assure that the final conditicn of nonconforming j
items will not' adversely affect safety, Code requirements, operability or maintainability of the items, or of the component or system in which it is installed.
Where ASME Code requirements are involved, disposition acceptance by the Authorized Nuclear Inspector shall be required.
Nonconforming items accepted "as-is," or reworked to an acceptable condition shall be identified through documentation records and in a manner that will establish the condition as installed.
Where an item is in non-conformance with ASME Code
- 26 requirements it shall not be dispositioned as "use-as-is".
When the responsible CECO personnel authorizes acceptance of the item "as-is," or rework of the nonconforming item, the action will be documented.
Such action involving vendor product prior to shipment to the site will be identified in shipping documents or certificates of conformance and reviewed _and approved by the site Quality Assurance Superintendent or the Station Quality Assurance Supervisor or their designees to assure that nonconformance has been resolved and corrective action completed.
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t Rejected items shall be identified by tagging and
.immediately removed from construction'or installation areas (unless-physical size prohibits this) and segregated in a controlled area to
- j prevent.its uncontrolled use or installation.
Commonwealth-Edison Company will make a technical evaluation-of pertinent data relating to the nonconformity, including the cause, 1
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l where known, and corrective action either taken or planned to prevent recurrence.
Also, items which are found to contain defects which could create a' substantial safety hazard will be reported in accord-ance with the provisions of 10CFR part ;21 and as provided in imple-menting' procedures.
Construction deficiencies involving material or equipment are documented and reported to the Nuclear Regulatory Commission and to Commonwealth executive management.
The Project Construction
. Superintendent or the Construction Superintendent or designee is responsible for this reporting.
q The Station Manager is responsible for investigating and reporting operating occurrences.
An Investigative Report.is prepared for occurrences or departures from the safety limits prescribed in'the Station Technical Specifications.
Occurrences and departures from the safety limits are documented and reported'to the NRC as required by the Technical Specifications.
The Station Manager appoints personnel to investigate the occurrence and issue an Investigative Report in accordance with the Technical Specifications and'a Quality Procedure.
This report is distributed to the Vice Presidents (Nuclear Stations Operations) and
- 45 Station Managers.
Reports of occurrences that result in significant damage or have significant safety implications are reviewed with the Vice president (Nuclear Operations) and then forwarded to the executive management.
The appointed personnel are responsible for determining the cause of the occurrence, developing recommendations intended to preclude recurrence and issuing a report which shall include:
a detailed description of the occurrence, the findings and recommended measures for corrective action.
When deviation from accepted normal operation of a reactor and its associated equipment occurs, or when a reactor scram occurs (other than those associated with a reportable occurrence), the Station Technical Staff investigates the deviation and issues a Deviation Report covering the nature of the deviation (e.g.,
process difficulty, equipment inadequacy, procedure inadequacy), its cause, Ethe hazard or potential hazard to operations and recommendations for corrective action.
15-2 Rev. 45 6/30/87 Commonwealth Edison
'The report documents the deviation and provides a record from which to establish a trend in the operation. Such reports are distributed to the Vice Presidents-(Nuclear Stations Operations), the Production
- 45
' Superintendent, Technical Staff Supervisor and Manager Quality-
.' Assurance._-The Assistant Superintendent Maintenance or Master Instrument Mechanic receive a copy of the deviation report if ruaintenance or ' instrumentation work is involved in the correction of the deviation.
Reports involving significant reactor _ safety considerations are reviewed with the cognizant Vice President (Nuclear Stations
- 45 Operations) and then forwarded to other' executive management.
Such deviations will be reported to the Nuclear Regulatory Commission
.as required by the Technical Specifications.
During construction the Project Engineering Project Engineer and during plant modification, the cognizant nuclear
- 45 stations Engineering or Production Services Department Project Engineer, as applicable, have responsibility for resolution of.
nonconformances.and such resolution will be approved by the Site Quality Assurance Superintendent or designee at the construction site or by the Station Quality Assurance Superintendent or designee at the operating station.
Nonconformance to system operation and technical specification requirements will be resolved through actions by the Production Superintendent with the approval of the Station Manager.
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i 16.O CORRECTIVE ACTION A corrective action system will be used to assure that such items as failures, malfunctions, deficiencies, deviations, defective material and equipment, nonconformances and programmatic deficiencies which are adverse to quality and might affect the
,29 safe operation of a nuclear generating station are promptly identified and corrected.
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Corrective action measures for nonconformances are included in the design, source fabrication and on-site construc-tion, erection and operational phases.
Corrective action measures 3
involving design will be processed as design change requests.
Corrective action measures in the source fabrication phase are required in the quality assurance programs of individual vendors including the NSSS Supplier.
For the Project Engineering-Construction phase and modifications undertaken by Station Construction, on-site correc-tive action measures shall consist of a program for: (1) reporting nonconformances to Engineering by Construction; (2) recording nonconformance reports (NCR's) in a log for follow-up by Quality Assurance as to resolution and satisfactory completion; (3) prompt resolution and approval of corrective actions by Engineering; (4) assurance by Construction that the corrective action has been taken; (5) sign-off approval and close-aut of NCR's by Site Quality Assurance that satisfactory corrective action has been taken; and (6) issuance by Engineering of monthly reports indicating the status of all NCR's submitted for resolution.
Implementation of corrective action will be accomplished at the source of deficiency by appropriate contractor personnel as found necessary by tha contractors or as directed by cognizant Edison engineers.
Project or Station Construction, as applicable has responsibility for implementation of the correction.
Quality Assurance is responsible for follow-up and final approval that the nonconformances have been corrected satisfactorily.
For corrective action nonconformances, the Edison Site Quality Assurance Superintendent or designee will establish and maintain a Nonconformance Report (NCR) Station Log to monitor the prompt resolution and closing of all NCR's plus maintain a file of all NRC's or equivalent documents that are submitted by the site for CECO resolution and approval.
16-1 Rev. 29 4/20/84 Commonwealth Edison
The cumulative monthly deviation report, which indicates the NCR number, deviation description and resolution, such as reject, replace, use-as-is or repair, approval status, date of resolution and whether corrective action is completed, is distri-buted to involved corporate and line management for information, review and possible action.
The responsible manager brings signi-l ficant nonconformances to the attention of corporate management for L
action where satisfactory resolution cannot be achieved by Engi-j neering with.a contractor.
1 For. Operations,. corrective action identified from noncon-1 formances, incidents and deviations, trend studies and audits are verified for satisfactory completion to preclude repetition.
When corrective action is required to correct nonconformance to Code requirements, such corrective action shall be made available
'to the Authorized Nuclear Inspector.
'Any revision to Travelers involved with corrective action related to nonconformance for station modifications shall be reviewed with the Authorized Nuclear Inspector for his review and insertion of hold points.
This system will provide follow-up to assure that corrective measures are effectively implemented.
Also, significant conditions are reported by the responsible manager and nonconforming items are routinely reported by the responsible engineering organization to appropriate levels of management.
The Technical Staff Supervisor verifies completion'of corrective actions for maintenance, repair, refueling and operation activities.
The Station' Quality Assurance Superintendent for mainten-ance and operating issues reports indicating the status of corrective action in progress.
These reports are routed to the Vice Presidents (Nuclear Stations Operations) and the Manager
- 45 Quality Assurance and reviewed to assure prompt implementation of the ccrrective action.
Site contractors and off-site vendors will be required to follow-up on corrective action commitments within their quality program.
The Site Quality Assurance Superintendent or designee will be responsible for surveillance of site corrective action.
The Project Engineering Project Engineer is responsible for assuring that review and evaluation of nonconformance reports are carried out to determine the need of corrective action.
Quality Assurance is responsible to track and verify completion of corrective action taken for audit deficiencies including programmatic deficiencies identified in audits.
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Required corrective action during Station operation which is due to equipment malfunctions and/ or abnormal occurrences will be incorporated into the Station maintenance and operating procedures in a timely manner to preclude repetition.
The responsible Quality Assurance Engineer or Inspector assigned to the Station verifies and approves the completion of corrective actions by the Station.
Deficiencies in implementing corrective actions will be brought to the attention of appropriate management levels for resolution.
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- 17. QUALITY ASSURANCE RECORDS
-Quality Assurance records will be maintained either by Edison or by an agent of Edison, under Edison's control. The i
location, means of identification, duration of retention and means of retrieval will vary depending on the nature of the individual records.
Quality Assurance records wil.1 be stored in a predetermined location as necessary to meet the requirements of applicable standards, codes and regulatory agencies and shall be
- 26 accessible to Edison.
The storage location or facility shall be adequate for the maintenance, preservation and protection of the Quality Assurance record files from the time of receipt until their ultimate disposal.
Fabrication and construction authenticated documentation
- 26 l
is generated by contractors and vendors for Commonwealth Edison Company, and will be available at the construction site or as directed by procurement documents.
Required documentation is
- 26 identified when records are stored at locations other than the site, a record will be maintained at the site to identify these records and their location (e.g., NSSS equipment documentation).
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Records generated during site construction, testing, operations and plant modifications will be ava.'lable at the Station as originals or reproduced copies.
Upon completion of construction
- 26 records will be. turned over to the Station for retention for the life of the plant.
l Station Quality Assurance records are retained and maintained by the Station personnel in accordance with written station procedures and regulatory and national Standard requirements.
The methods of storage, preservation and safekeeping of the records are selected to minimize damage, deterioration or loss.
Quality Assurance records are identifiable and retrievable.
These records include items which are related to the safe operation of the Station; which document the as-built requirements of equipment and systems for use in maintaining, reworking, repairing or modifying station equipment; which can assist in determining the cause of a malfunction of an item that provides protection to the health and safety of the public; and which provide inspection data for in-service inspection.
17-1 Rev. 26 12/10/83 Commonwealth Edison
The lifetime quality assurance recteds, including audit reports are those continually maintained for the operating life of particular ASME Code and safety-related item or component while it is installed in the Station or stored for future use.
Records to be kept as required >for the life of the plant shall be designated. For ASME items, lifetime and nonpermanent records shall be maintained as provided by Section III of the ASME Code.
The Director of Quality Assurance (Engineering /
Construction) will be responsible for assuring records are retained by Project Construction during engineering and construction.
Following start-up, the Station Manager will be responsible for che retention of station operating, maintenance and modification records for the life of the plant or for the period of time established by Commonwealth Edison Company Procedures.
Records retained shall be identifiable and retrievable.
Thec certified design specification and a copy of acceptance verification for the design reports for safety-related and ASME Section III Division 1 items and the certified design and construction specifications, and certified design and construction reports for ASME Division 2, concrete containment, will become part of the permanent records file to be retained for the life of the item or the life of the plant, at the plant site, the manufacturing plant, the Architect Engineer or other designated locations.
Files shall be maintained current, complete and available i
for audit by Commonwealth Edison Company or its agents, the Nuclear Regulatory Commission and the Authorized Nuclear Inspector at any reasonable time during the retention period.
Contractors and suppliers shall retain their quality records as required by applicable codes, standards and contract requirements.
At the end of the required retention period, the conttactor or supplier shall transfer these records to the Commonwealth Edison Company Project Construction Superintendent or Construction Superintendent or designee for transfer to the Station Manager or filing for the life
- 39 of the plant. In no case will the file be destroyed by the contractor or vendor without written instrketion by Commonwealth Edison.
17-2 Rev. 39 11/20/85 Commonwealth Edison I
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- 18. AUDITS Audits will be performed by Commonwealth Edison Company and/or its contractors, subcontractors and vendors to verify the implementation and effectiveness of quality programs under their cognizance.
The number and experience of persons participating in audits will vary according to the nature and significance of the audit.
Audits under the responsibility of the Manager of Quality Assurance will cover quality systems for engineering, construction, modifications, maintenance, in-service inspection and Stores activ-ities.
Audits will be performed to evaluate the implementation of
- the quality assurance programs and the adherence to procedures and controls and the fulfillment of requirements.
Certifications and records will also be evaluated.
produc t audits assess the
. effectiveness of in-progress work, inspections and tests that are specific to the fabrication, installation, construction, testing and operation of an item.
The performance and compliance of each operating station to the Quality. Assurance Program is assured through review surveil-lance and audit of operations by the Quality Assurance Engineer or Inspector under the direction of the Station Quality Assurance Superintendent who is responsible for operating quality assurance to the Director of Quality Assurance (Operations) and through
- 45 review, surveillance and audit of maintenance, modifications, Stores and in-service inspection activities by Quality Assurance Engineers or Inspectors (Maintenance) under the direction of the Station Quality Assurance Superintendent who is responsible for such quality assurance activities to the Director of Quality Assurance (Maintenance).
Audits are performed to audit schedules which are approved by the Manager Quality Assurance.
This i
schedule includes the minimum audits required.
Other audits will be performed as directed by Quality Assurance Supervision.
The Lead Auditor's auditing organization shall develop and document an audit plan for each audit.
This plan shall identify the audit scope, requirements, audit personnel, activities to be audited, organizations to be notified, applicable documents, schedule, and written procedures or checklists.
Audits will be conducted using checklists or an agenda approved by responsible Quality Assurance Department personnel and will be conducted with sufficient authority and organizational freedom to evaluate compliance with all applicable aspects of the Quality i
Assurance Program and specified requirements.
Audits will be initiated early to assure effective quality assurance during design, l
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procurement, manufacturing, construction and installation, inspection and test and be performed efficiently in order to achieve o
a minimum of interference with work in progress and minimum disruption of organizations being audited. An audit plan will be maintained in order to schedule audits of site contractors.
Audits e
of off-site contractors generally will be conducted in conjunction with plant visits for witnessing inspection points by a qualified auditor.
Also, periodically Quality Assurance will participate in such audits or perform independent audits to assure effectiveness of the program, compliance to the program and fulfillment ot procurement requirements.
The elements in the quality program, in procurement docu-ments and in related codes and standards, are subject to systems audits.
Also, items received, fabricated and constructed or installed for use by Commonwealth Edison Company in its nuclear power plants are subject to audits.
Audits will be performed selectively at various stages of contracts on a varying frequency, based on the nature and safety significance of the work being done to verify compliance and determine the effectiveness of procedures, inspections, tests, process controls and documentation.
For Code materials, when a Material Manufacturer or Material Supplier, as applicable, does not hold a Quality System Certificate (Materials), the CECO audit frequency shall be at least once annually during the interval in which CECO purchased material is being controlled by the Material Manufacturer or Material Supplier.
In addition to these audits, Quality Assurance will conduct approximately annually, overall system audits of the NSSS vendor, the Architect Engineer, site contractors, vendors of services, and involved Edison Departments.
Audits of CECO are also performed by the Authorized Inspection Agency as required by the ANSI N-626 series of Standards.
For operating stations, periodic Quality Assurance Depart-ment audits will be performed to verify compliance with, and the effectiveness of the program.
Audits covering operating will be performed in accordance with the Technical Specifications under the direction and responsibility of the Director of Quality Assurance (Operations) independent of the Production Department.
- 45 Surveillance, review and audits covering maintenance, modifications, in-service inspection and Stores activities will be performed under the direction and responsibility of the Director of Quality Assurance (Maintenance).
Audit results and recommendations of corrective action will be documented and reviewed with the management of the Station.
Deficiencies requiring prompt corrective action are reported immediately to management of the audited organization.
Verification of the completion of corrective action recommended in audit reports will be performed by the Technical Staff Supervisor or Quality Control Supervisor.
Follow-up of open station items is tracked by the Action Item Records (AIR) System.
Where an audit item is placed under the AIR system for tracking completion, approval as to satisfactory completion of corrective action shall be obtained from the responsible station Quality Assurance Engineer or Inspector.
18-2 Rev. 45 6/30/87 Commonwealth Edison
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Audits will be established and conducted by qualified i personnel who are-familiar with written procedures, standards and L
- processes applicable to the area being audited, but whc, do not have l
' direct responsibilities in the areas being audited.
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A report shall be written for each audit.
An audit report package consisting.of Summary Sheet, Attachment Sheet, Checklists or Agenda and any additional pertinent details recorded on additional sheets necessary to support a finding (s) will be on file.
The audit report will be reviewed, signed, and dated by the Lead Auditor and should be signed by the auditor (s).
The audit shall be reviewed for acceptability by a supervisor.
The audit report shall be sent, as applicable, to the Executive Vice President, Senior Vice President
- 45 (Engineering), Senior Vice President (Nuclear Operations), Manager of Station Construction, Manager of Projects, the cognizant nuclear stations Engineering and Production Services Managers, Manager Quality Assurance and the Directors of Quality Assurance and Vice Presidents (Nuclear Stations Operations) for management review
- ss and action.
The above stated system audits are also sent to the Chairman and President for review and evaluation and action as deemed necessary by the Manager Quality Assurance.
Also, monthly to bi-mcnthly periodic reports on quality assurance activities are submitted to top management.
Such reports, in part, provide bases for periodic top management reviews and discussions of quality assurance activities, implementation status and effectiveness.
Such reviews and discussions are held by the Chairman and President with the Menager Quality Assurance and with other executives.
Audits shall be scheduled and follow-up review of ' deficient areas or adverse donditions and follow-up on corrective action commitments shall be performed by Quality Assurance to assure effective corrective action and implementation have been carried out.
Deficiencies in the execution or implementation of correc-tive action will be brought to the attention of the person who is responsible in the area involved.
Continued deficiencies, or failure to implement corrective action will be reported in writing by Quality Assurance to appropriate executives within Commonwealth Edison Company.
18-3 Rev. 45 6/30/87 Commonwealth Edison
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