ML20236C352

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Summary Description of QA Program
ML20236C352
Person / Time
Site: Limerick Constellation icon.png
Issue date: 06/22/1987
From:
PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:
Shared Package
ML20236B676 List:
References
NUDOCS 8707300024
Download: ML20236C352 (45)
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LIMERICK GENERATING STATION UNIT 2

SUMMARY

DESCRIPTION OF THE j l - l I

QUALITY ASSURANCE PROGRAM 1 e

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8707300024 070709 PDR ADOCK 05000353 A PDR 06/22/87

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> LGS l 2 o 3, s APPENDIX D l QUALITY ASSURANCE PROGRAM l

TABLE OF CONTENTS l D.1 INTRODUCTION D.2 GENERAL D.2.1 Scope and General Approach D.2.2 Organization and Definition of the Philadelphia  ;

Electric Company Quality Assurance Program '

D.2.2.1 First Level-Quality Control and Inspection D.2.2.2 Second Level-Quality Assurance Surveillance D.2.2.3 Third Level-Quality Assurance Auditing D.2.2.4 Program Plans D.3 PHILADELPHIA ELECTRIC COMPANY QUALITY ASSURANCE PROGRAM l l

D.4 FIRST LEVEL ORGANIZATION QUALITY CONTROL. REQUIREMENTS D.4.1 Organization D.4.2 Planning  ;

D.4.3 Control of Special Processes, Tests, and Inspections j D.4.4 Control and Identification of Material, Parts and Components 1 D.4.5 Control of Purchased Material, Equipment and Services l D.4.6 In-Process and Final Inspection {

D.4.7 Control of Inspection Status D.4.8 Control of Measurements, Inspection and Testing j

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Equipment ]

D.4.9 Handling, Storage, Shipping and Preservation i D.4.10 Control of Non-Conforming Material, Parts, Equipment or Workmanship D.4.11 Control of Quality Records D.4.12 Corrective Action D.4.13 Control of Specifications, Drawings, Procedures and Instructions D.4.14 Quality Control Program Documentation l 1

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D.5 GENERAL ELECTRIC QUALITY ASSURANCE PROGRAM D.5.1 Management D.5.2 Preparation of Specifications and Drawings D.5.3 Procurement of Equipment D.S.3.1 Equipment Manufactured by Other Companies D.S.3.2 Components Manufactured by General Electric - NEBO Departments D.5.4 Construction Site D.6 BECHTEL QUALITY ASSURANCE PROGRAM D.6.1 Project Management D.6.1.1 OA Surveillance of Project-Engineering Activities D.6.1.2 QA Surveillance of Construction Site Activities -

D.6.1.3 Auditing D.6.2 Engineering l D.6.2.1 Preparation-of Specifications and Drawings-D.6.2.2 Procurement Activities j l

D.6.3 Procurement D.6.4 Construction i

D.7 DESIGN CONTROL D.7.1 Philadelphia Electric Company D.7.2 General Electric Nuclear Energy Business Group - NEB 0 D.7.3 Bechtel D.7.4 Engineering & Design Consultants l l

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., $ LGS l APPENDIX D i i

OUALITY ASSURANCE PROGRAM i 1

I LIST OF FIGURES l

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i FIGURE NUMBER TITLE D.l.1 Philadelphia Electric Quality Assurance Organization for Limerick Generating Station D.2.1 Quality Assurance Program Functional Organization and Communication 1

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QUALITY ASSURANCE PROGRAM LIST OF TABLES 1

TABLE NUMBER TITLE D.2.1 Summary Q-List i I

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, LGS APPENDIX D QUALITY ASSURANCE PROGRAM D.1 INTRODUCTION Philadelphia Electric Company has the responsibility to assure that the Limerick Generating Station Unit 2 is fabricated and l

constructed in accordance with applicable regulations, codes, and specifications. Accordingly, Philadelphia Electric has established a comprehensive quality assurance program which starts with the initial station design and carries through all phases of equipment procurement, fabrication, erection and construction. This program provides for review of specifications to ensure that necessary cuality control requirements are included and for the performance of quality assurance surveillance and audits to ensure that specified requirements are met.

Philadelphia Electric has established an organization to l implement this quality assurance program. The Philadelphia i i Electric Director, Quality Assurance Division is. responsible for l coordinating the program to assure that all necessary quality control requirements and procedures are followed during all l phases of design, shop fabrication, and site construction. The {

main participants in this quality assurance program other than j Philadelphia Electric itself, are General Electric Nuclear Energy j Business Operation and Bechtel.  !

l The Philadelphia Electric Manager, Quality Assurance Limerick 2 l is assisted by various consultants in monitoring the quality 1 assurance performance of General Electric, the various divisions of Bechtel, and their subcontractors. A chart describing Philadelphia Electric's organization as related to the Quality Assurance Program is shown on Figure D.l.1.

The QA program described herein is modified as applied to the design and fabrication of the High Density Spent Fuel Storage Racks. Philadelphia Electric Company shall be responsible for developing the equipment specification for the Spent Fuel Storage  ;

Racks, for evaluating bids, vendor selection and procurement for I review of the vendor's design, and for surveillance of the vendor l up to the point of delivery at the construction site, at which time the Racks shall come under the Bechtel Construction QA/QC program. Philadelphia Electric Company shall issue procedures to control activities affecting quality which are performed by Philadelphia Electric and for surveillance of the vendor. The equipment specification shall impose appropriate QA program requirements on the vendor.

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[heQualityAssuranceprogramdescribedhereinismodifiedas I

applied to the activities related to the Reactor Pressure Vessel (RPV) safe end removal and replacement and the Peedwater Closure l

Welds to the Reactor Pressure Vessel safe ends. Philadelphia 3 Electric Company (PECo) shall be responsible for developing the administrative and quality assurance requirements, for preparing and issuing purchase orders, for review and approval of the subcontractor's Quality Assurance Plan and procedures, and for second level audit of the subcontractor's activities. PECo shall issue procedures to control the activities affecting quality which are performed by PEco and for audit of the subcontractor.

The subcontractor shall issue procedures as required by the purchase order to control their activities which affect quality including first level inspection and audits. The technical requirements for the Reactor Vessel removal and replacement work are prepared by General Electric NEBO. The technical requirements for the welding and nondestructive examination of the Feedwater Closure Welds to the Reactor Vessel safe ends are supplied by Bechtel.

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1 LGS D.2 GENERAL D.2.1 Scope and General Approach The quality assurance program described herein applies to those structures, systems, and components of reactor facilities which are essential to the prevention of accidents which could affect the public health and safety or to mitigation of their consequences.

Those '

structures, systems, and components which are considered as

" essential" are listed in Table D.2.1, in summary. Details are shown ;

in the Project Q-List and the Quality Assurance Diagrams (QAD's).

The quality assurance program starts at the initial design phase with development of specifications and/or associated purchase documents which contain quality control and inspection requirements, and proceeds through the selection of the supplier manufacture of the components or systems, and erection and installation. Specific quality control requirements cover such areas as material control, welding requirements, nondestructive testing requirements, provisions for comprehensive auditing of manufacturers' or constructors' efforts, the preparation and retention of quality control records, etc., and will be included, as appropriate, in the various specifications and/or associated purchase documents. General Electric NEBO and Bechtel, as Philadelphia Electric's design contractors, are res*ponsible for seeing that the necessary quality control requirements are included <>r referenced in the component and construction specifications and/or associated purchase documents for which they are responsible.

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Where specifications include interfaces between major contractor responsibilities, quality control requirements will be jointly established.

Specifications and/or associated purchase documents pertaining to the

" essential" items receive at least one independent review for ,

evaluation of quality control requirements. I The selection of a component manufacturer or field erection and installation subcontractor is made only after it has been ascertained that his organization has the necessary quality control capability and the qualified personnel to provide the level of integrity required for the equipment or construction involved.

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LGS The quality control programs of component manufacturers, subcontractors, and Bechtel Construction are normally under the audit / surveillance of the Philadelphia Electric contractor (GE-NEBO or Dechtel) which is responsible for that portion of plant design. This quality assurance effort by the appropriate Philadelphia Electric contractor is in addition to the quality control and inspection programs of the individual raanufacturer or site constructor. The purpose of this effort is to assure that the work of the various manufacturers and constructors is actually proceeding in accordance with the specification or other approved progrem requirements. A description of the Quality Assurance Programs of General Electric and Bechtel is contained in subsections D.5 and D.6 respectively. 1 In addition, to assure that the quality assurance program is functioning as desired, Philadelphia Electric conducts quality l l assurance audits on a spot-check basis, on the quality programs of l General Electric-NEBO, Bechtel and their subcontractors.

D.2.2 Organization and Definition of the Philadelphia Electric

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Quality Assurance Program i Figure D.2.1 is an overall functional Quality Assu ance Chart showing the working relationships between Philadelphia Electric and its contractors for the Limerick Generating Station. fhis Quality Assurance Program is divided into three levels. These levels are indicated on the left hand side of Figure D.2.1. The definitions and i functions of the three levels indicated on the organization chart are '

described in the following subsections.

D.2.2.1 First Level-Quality Control and Inspection The First Level is defined as the Quality Control and Inspection function. Component manuf acturers are require:d contractually to have a quality control and inspection program. Be(htel Construction performs first level inspection on Bechtel site activities and selected on-site subcontract activities. Subcontractors are required to either provide a quality control and inspection program, or may have first level inspection performed by Bechtel Construction. Each inspecting agent has the responsibility to ensure that the fabrication / construction activities meet specification requirements.

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. $ LGS For those cases that Bechtel Construc ion subcontracts site l construction work (e.g. Containment Vessel), the subcontractors are required to either provide a quality control and inspection program, or may have first level inspection performed by Bechtel Construction.

Bechtel Construction performs first level inspection on Bechtel site activities and selected on-site subcontract level inspection on Bechtel site activities and selected on-site subcontract activities.

Bechtel Construction performs a second level surveillance function on the subcontractor's Quality Control and Inspection efforts when first level surveillar;ce is performed by the subcontractor. In certain cases where the subcontractor provides first level inspection, Philadelphia Electric Company may elect to retain responsibility for both second level and third level Quality Assurance audit / surveillance activities, where Philadelphia Electric Company has a particular interest in the subcontractor. In these cases, Philadelphia Electric Company will implement more comprehensive Quality Assurance audits than the normal third level activity would require.

D.2.2.2 Second Level-Ouality Assurance Surveillance The Second Level, which is defined as a Quality Assurance Surveillance function includes auditing and/or surveillance, performed by the Philadelphia Electric contractor (General Electric NEBO or Bechtel) which is responsible for furnishing the requirement' specifications for materials, components, construction, and installation which in turn are used by the first level groups.

When Bechtel Construction subcontracts site construction work, the l Quality Assurance Surveillance function is normally performed by Bechtel Corporation. In certain cases where the subcontractor provides first level inspection, Philadelphia Electric Company may elect to retain responsibility for both second level and third level Quality Assurance audit / surveillance activities, where Philadelphia Electric Company has a particular interest in the subcontractor. In these cases, Philadelphia Electric Company will impleraent more comprehensive Quality Assurance audits than the normal third level activity would requite.

The Philadelphia Electric contractors which perform this second level function each have quality assurance capability which is used by their respective organizations in assisting in this quality effort. This quality assurance capability includes personnel with technical backgrounds in appropriate disciplines (e.g., electrical, mechanical, civil).

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. . LGS D.2.2.3 Third Level-Quality Assurance Auditing The Third Level is defined as the Quality Assurance Auditing function l performed by Philadelphia Electric. Selected QA Consultants assist Philadelphia Electric in implementing this program. The purpose of this quality assurance function is to ensure that the overall Quality Assurance Program is functioning as planned. To accomplish this, Philadelphia Electric reviews, prior to order placement, specifications and associated purchase documents furnished by the design contractors (General Electric NEBO and Bechtel) to ensure that l the necessary quality requirements have been incorporated in these documents. In addition, on a spot-check monitoring basis, Philadelphia Electric performs quality assurance audits to ensure that the Quality Programs of the first and second level groups are actually functioning as required.

D.2.2.4 Program Plans l Detailed descriptions of the Philadelphia Electric, General l

Electric-NEBO, and Bechtel programs which contain guidelines, l criteria, organizational responsibilities, and other pertinent information for the implementation of the Philadelphia Electric Quality Assurance program will be contained in the,following quality assurance plans.

a. Philadelphia Electric Quality Assurance plan for Limerick Generating Station Unit 2, Volume I.,

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b. General Electric-NEBO Boiling Water Reactoc l Quality Assurance Program Description, NEDO-ll209, (Latest Revision)
c. Bechtel Nuclear Quality Assurance Manual, (Latest Revision)

The foregoing QA plans used to implement the quality assurance program 1 described herein may be revised to incorporate improvements which l l evolve as experience is gained. These detailed quality assurance plans will be available to NRC personnel as they perform audits to evaluate the implementation of the Philadelphia Electric Quality .

Assurance Program. l l

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1 D.2.2.5 Application of the Quality Assurance Program The Quality Assurance program has been expanded to include the following systems and/or items of activity.

(1) Fire Protection The Quality Assurance Program applies to fire protection equipment including fire sensing, fire suppression, emergency lighting, and communication equipment in safety related areas and in the main turbine lube oil reservoir area.

(2) Base-Line Preservice Inspection This Quality Assurance program applies to the base-line preservice inspection except that there will be a two level program concept instead of three level for actual base line l l inspection activity at the plant. The first level will be l the contractor / subcontractor's, including surveillance and l auditing as contractually required. The Second Level is the PECo quality assurance auditing function.--

(3) Pre-Operational Test Phase The Quality Assurance Plan applies to the Pre-Operational Test Phase with two exceptions. These exceptions are; l) that PECo Nuclear Operations is responsible for the direction l of the preoperational and acceptance tests conducted by the Startup organization and 2) the two level program concept will be used instead of the three. level. The first level is that of the testers (quality control) and the second level is the PECo quality assurance auditing (and where appropriate)

QC inspection functions. Based on the fact that the preoperational test phase responsibilities cover both Engineering and Research and Nuclear Operations activities, l the audit responsibilities have been divided between the l respective QA groups (Engineering and Research QA Division and Nuclear Operations OA Division).

(4) High Density Spent Fuel Storage Racks The Quality Assurance Program applies to the design and fabrication of the "as modified" high density spent fuel storage racks.

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., a (5) Reactor Vessel Safe End Removal and Replacement and Feedwater Closure Weld to Reactor Vessel Safe End The Quality Assurance Program is applied to the activities related to the Reactor Pressure Vessel (RPV) safe.end removal and replacement and the Feedwater Closure Welds to the Reactor Pressure Vessel safe ends as described in the Quality Assurance Plan. Philadelphia Electric Company (PECo) shall be responsible for developing the administrative and quality assurance requirements, for preparing and issuing purchase orders, for review and approval of the subcontractor's Quality Assurance Plan and procedures, and for second level audit of the subcontractor's activities. . PECo shall issue procedures to control the activities affecting quality which are performed by PECo and for audit of the subcontractor.

(6) Emergency Response Facilities Data Acquisition' System (ERFDS)

The quality assurance program is applied to the purchase of the ERFDS as described in the Quality Assurance Plan. PECo shall be responsible for developing the purchase specification, for evaluating bids, vendor selection and procurement, for review of the vendor's design and for audit of the vendor's design and field activitie,s.

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SUMMARY

0-LIST {

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I. Civil-Structural Reactor Building Primary Containment Diesel-Generator Building, Control Room Area Complex and Intake Structure Housing Critical Pumps Diesel Fuel Storage Facilities Supports for Nuclear Class I and II System Components ,

Spent Fuel Pool l II. Mechanical Reactor Assembly Fuel Assembly Reactor Vessel _~

Reactor Vessel Support Reactor Vessel Stabilizer Shroud and Shroud Support, including Core Spray Sparger Core Spray Line Core Support Top Guide Orificed Fuel Support i

Control Rod including Velocity Limiter Control Rod Drive Control Rod Drive Housing Control Rod Drive Housing Support Jet Pump Assembly l Power Range Neutron Detectors LCPI Coupling Plange Nuclear Boiler System i Reactor Vessel Relief Valves Reactor Vessel Safety Valves Main Steam Line Flow Restrictors Main Steam Piping and Isolation Valves Main Steam Line Suspension Selected Instrumentation i Selected Valves l

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' O l Reactor Recirculation System '

Recirculation Pumps Recirculation Valves Recirculation Piping Recirculation Loop Suspension Recirculation Loop Restraints Selected Instrumentation Control Rod Hydrauli__c System l

Portions of the Hydraulic Control System necessary for Scram !

Standby Liquid Control Systems k Standby Liquid Control Tank Accumulator '

Pumps Explosive Valves Selected Instrumentation Selected Piping, Valves and Suspension Neutron Monitoring System Intermediate Range Monitor '

Average Power Range Monitor including Local Power Range Monitor Inputs l Residual Heat Removal System Heat Exchangers Pumps Selected Instrumentation Selected Piping, Valves and Suspension RHR Service Water System RHR Service Water Pumps RHR Service Water Piping, Valves and Suspension Instrumentation Core Spray System Core Spray Pumps j Selected Instrumentation Selected Piping, Valves and Suspension 06/22/87 D.2-8

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High Pressure Coolant Injection System HPCI Pump HPCI Turbine Selected Instrumentation Selected Piping, Valves and Suspension Reactor Core Isolation Cooling System  !

RCIC Pump RCIC Turbine Selected Instrumentation Selected Piping, Valves and Suspension Primary Containment and Reactor Vessel Isolation Control System s 1

Trip Systems A and B Isolation Initiation Channels  !

I Incident Detection Circuitry l Core Standby Cooling Systems Initiating-~

Channels and Logic Automatic Depressurization System Initiating Channels and Logic '

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Drywell Drain Isolation Valves Reactor Water Cleanup System Piping, Valves, Suspension and Instrumentation within Primary Pressure Boundary Service Water Systems Serving Engineered Safeguards Equipment Reactor Building Recirculation System Fans Duct Work and Pipe including Reactor Building Vent Valves and Dampers i Instrumentation

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High Density Spent Fuel Storage Racks  !

Standby Gas Treatment System Fans and Filters Duct Work and Pipe Valves and Dampers Suspension System Instrumentation 06/22/87 D.2-9 i

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RCIC, HPCI RHR and Core Spray Rooms Control Room Ventilation Supply System Emergency Switchgear Room Ventilation i l

Reactor Building Isolation Control System Reactor Building Recirculation System Primary Containment Atmosphere Control System through Isolation Valve Reactor Building Crane III. Electrical

'i Standby Diesel Generator -

Including Cooling and Fuel Supply Systems Electrical Power System Associated with Safety Related System Control Room Panels (Safety Related)

Local Panels and Racks (Safety Related)  ;

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D.3 PHILADELPHIA ELECTRIC COMPANY QUALITY ASSURANCE PROGRAM _

The Philadelphia Electric quality assurance program has been developed with the 18 Criteria of 10CFR50, Appendix B (hereinafter referred to as NRC QA criteria) as its basis It provides a systematic, controlled method of applying these NRC QA Criteria at all levels of the Limerick project and establishes a means of follow-up and evaluation to ensure that the intent of these criteria are actually met.

l More specifically, Philadelphia Electric requires of its contractors, l General Electric-NEBO and Bechtel, that they meet the provisions of l the NRC criteria and that the applicable requirements be invoked upon l ,

j their vendors. The plant constructor and site subcontractors are required to meet the same type of quality control provisions. This is accomplished as follows:

a. Quality control provisions are specifically applied to first level vendors, through a generic quality assurance specification (Bechtel) or-specific quality l control plans (General Electric) coupled with provisions of applicable specifications, drawings, and purchase documents. The contractors"will designate the essential equipment depending upon such considerations as the safety related function to be performed, its importance to the overall system, and whether it is duplicated in redundant installation. Appropriate NRC criteria will be applied to each component.
b. The quality control requirements to be placed on key vendors, the constructor, and selected site subcontractors will be reviewed by Philadelphia Electric.
c. The quality control capability of potential vendors i will be evaluated by General Electric-NEBO and Bechtel.

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d. The Philadelphia Electric three level quality assurance program identifies a clear line of responsibility for implementing quality requirements and provides a means for ensuring that the quality requirements specified are being met. This, the first level vendors, the constructor, and the site subcontractors are required to have their own inspection and quality control efforts to cssure that specifications and other requirement documents are met. The second level quality assurance audit or surveillance functions performed by General Electric-NEBO and Bechtel provides a means for ensuring the work carried out by the vendors, constructor, and subcontractors meet specified requirements. Finally, the third level Philadelphia Electric quality assurance effort provides a separate and independent monitoring of the overall QA program to ensure that it is functioning as planned.

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e. Pertinent inspection, quality control, and quality assurance documentation will be maintained for this project. -

The Philadelphia Electric Director, Quality Assurange Division is l l responsible for coordinating the quality assurance program. The l Philadelphia Electric Manager, Quality Assurance Limerick 2 has the l l

I authority to stop work. The overall organization of this program is  ;

shown on Figure D.2.1. Philadelphia Electric will station Quality '

Assurance Engineers at the construction site to audit the construction and installation work. These site Quality Assurance Engineers report  !

to Philadelphia Electric Manager, Quality Assurance Limerick 2. l Assistance from Philadelphia Electric Engineering and Research engineers is available to the Director, Quality Assurance Division. l l

I Various divisions of the Philadelphia Electric Company or consultants )

assist the Philadelphia Electric Manager, Quality Assurance Limerick 2 l l in monitoring the overall Quality Assurance Program. Philadelphia Electric has retained selected QA consultants to assist in monitoring l

this program. This assistance is in conjunction with the quality ,

functions that are performed by Philadelphia Electric and its contractors and their subcontractors, as follows: j i

a. Review of specifications, drawings, procedures, 1

inspection check-off lists, and other pertinent documents to assure that the quality control and test requirements for components and systems are included. (

b. Periodic quality assurance audits and checks at manufacturer's plants and at the site to evaluate the performance of Philadelphia Electric contractors and subcontractors in implementing the specified quality control and testing requirements and maintaining necessary records.

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c. Witness, on a spot-check basis, tests on components and systems.

In the performance of the Quality Assurance tasks, the QA consultants will advise the Philadelphia Electric Director, Quality Assurance Division or the Philadelphia Electric Manager, Quality Assurance Limerick 2, as appropriate, of any deviations or deficiencies found during quality assurance audits of component fabrication and site construction, so that corrective action can be taken without delay.

Philadelphia Electric uses written procedures or checklists for reviewing documents and performing quality assurance audits. The reviews, audits, and follow-up action are documented.

Beginning February 1983, Philadelphia Electric initiated the performance of field quality control inspections.

These PECo QC inspections are performed on the various systems as completed by Bechtel and turned over to PECo.for field test and calibration of instruments. The inspections ar'e documented on a Quality Control Inspection Report (QCIR).

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. $ LGS D.4 FIRST LEVEL ORGANIZATION OUALITY CONTROL REQUIREMENTS When deemed appropriate by Bechtel and General Electric-NEBO, the equipment vendors and subcontractors will be required by the f applicable equipment or construction specifications and/or associated i purchase documents to have a quality control program. In addition,  ;

Bechtel Construction will have a Quality Control Program. These I programs shall cover the necessary quality control requirements for l the fabrication, installation, testing, or construction of the

" essential" portions of the plant and shall include appropriate elements of the following items:

D.4.1 Organization The vendor (in this subsection, the term " vendor" shall' include Bechtel site subcontractors) shall have a qualit y control organization which has the authority and responsibility for seeing that the quality l control program is established, planned and implemented. The quality j control organization shall delineate its responsibility and duties in l writing and shall provide sufficient organizational freedom to permit i identification of quality control problems and init4ation of {

appropriate corrective action. (

D.4.2 Planning ' k j

The vendor, during the earliest practical phase of contract performance, shall conduct a review of the requirements of the contract and take timely action to ensure that necessary quality control procedures and provisions are established in accordance with the applicable specifications, codes and standards. In particular, the vendor shall make timely provisions for having the required qualified personnel available and written procedures of this program in effect prior to their actual use in manufacturing or fabrication of the item under contract. l Bechtel and General Electric will judge quality assurance programs against the quality assurance requirements invoked in the specifications and purchase orders. In addition, Philadelphia Electric will monitor this work to assure that an adequate evaluation has been made.

j The adequacy of the implementation of these programs is assessed by l the surveillance or auditing performed by the second level contractors. Philadelphia Electric, through spot check audits, will evaluate the adequacy of implementation of vendor and second level quality assurance programs.

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._ '. LGS D.4.3' Control of Special Processes, Tests and Inspections

1. The vendor shall operate under a controlled manufacturing system and shall have written procedures or instructions for control of special fabrication and construction processes such as welding, heat treatment, cleaning, control of tools and fixtures, weld electrode control, concrete production and placement,_special l equipment installat' ion at the construction site, etc. j
2. The vendor shall have written procedures for control of the required testing and inspection programs on the l

item under contract. These procedures shall cover all l nondestructive' testing (radiography, magnetic particle, I liquid penetrant, ultrasonic, etc.) weld fit-up inspections, soap bubble tests, hydrostatic tests, etc.

l D.4.4 Control and Identification of Material, Parts, and Components The vendor shall have written procedures for assuring the control, identification, and location of materials, parts, and components used  ;

in the finished item under contract.  !

l D.4.5 Control of Purchased Material, Equipment and Services The vendor shall have written procedures to assure the control of purchased material, equipment, and services, including such items as l purchase documents, receiving inspection, identification and l certification of incoming material and equipment to ensure that it '

conforms to the requirements of the purchase specification. In addition, the vendor is responsible for assuring that supplies and services procured from his subvendors conform to the contract requirements considered applicable. The vendor shall further provide for the submittal of required quality plans and documentation frem his l subvendors and shall, as appropriate, obtain the right of source-  !

inspection and visitation for himself and/or his representatives.

1 D.4.6 In-Process and Final Inspection  !

The vendor shall have written and documented In-Process and Final Inspection Programs for the item under contract. As a portion of these plans, the vendor shall establish an inspection and testing plan, check-off lists, or other suitable systems to assure that i required inspection and tests are performed and to provide records of their performance. Such plans shall indicate, as appropriate, inspection points to be witnessed and witnessing organizations. 1 l

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D.4.7 Control of Inspection Status The vendor shall have a system designed to assure that the current inspection status of the item under contract is known at all stages in the production process. This may be accomplished by means of stamps, tags, routing cards, multicolor tape, or other suitable methods.

D.4.8 Control of Measurements, Inspection and Testing Equipment l The vendor shall have written instructions governing the control of i measurement, inspection and test equipment. These instructions shall include, as appropriate, calibration to standards traceable to nationally recognized standards, accuracy requirements, and recalibration frequency requirements.  ;

D.4.9 Handling, Storage, Shipping and Preservation

1. Where appropriate, equipment vendors shall have oritten instructions to govern the handling, storage, shipping, ,

and preservation of the items under contract so as to  !

prevent degradation of the quality below that required by the applicable equipment specifications.

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2. Similarly, site installation and construction contractors shall have written instructions to govern the handling, storage, and preservation of equipment prior to and after installation.

D.4.10 Control of Non-Conforming Material, Parts, Equipment or Workmanship The vendor shall have written procedures governing the identification, control, and disposition of materials, parts, or equipment that do not meet specification requirements. Repairs shall be in accordance with documented instructions. Major repairs shall be in accordance with documented procedures approved by General Electric or Bechtel.

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D.4.11 Control of Quality Records '

There shall be written requirements governing the accumulation, j storage, and disposition of appropriate manufacturing, installation,  !

construction, inspection, test, and quality control records for the item under contract. There shall be a specific list of records which i the vendor will turn over to General Electric or Bechtel (as appropriate) for transmittal to Philadelphia Electric, and/or those which shall be maintained for the life of the plant (i.e., 40 years).

This list shall be in compliance with the contractual arrangement between General Electric and Philadelphia Electric concerning records to be provided to, or maintained for, Philadelphia Electric. The vendor procedures governing the control of records he retains shall describe what steps he will take to ensure that these records will be adequately stored and readily retrievable for the life of the plant, j Quality control records produced by Bechtel and obtained from vendors I will be accumulated and turned over to Philadelphia Electric at the end of the job.

D.4.12 Corrective Action The vendor's quality control program shall provide for quality information reporting to management and others having quality system responsibility concerning the overall etatus of product quality and quality-related plans and programs. The program shall provide input for the initiation of corrective action and follow-up as appropriate.

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D.4.13 control of Specifications, Drawings, Procedures, and Instructions The vendor shall have written procedures governing the control and use of specifications, drawings, and the various work, test, and inspection procedures. The procedures shall indicate how the vendor assures that only appropriately approved versions of specifications, drawings, and procedures are actually used by his work force and inepection personnel. In addition, the vendor shall obtain the concurrence of General Electric-NEBO or Bechtel Engineering (as appropriate) to changes in specifications, drawings or proceduren which the latter originally prepared or approved.

D.4.14 Quality Control Program Documentation Quality control documentation of vendor work will be maintained in accordance with written requirements contained in the applicable generic quality control specification (Bechtel) or quality control plans (General Electric-NEBO), individual specifications, and purchase order requirements.

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, ', LGS General Electric-NEB 0 and Bechtel will maintain the specified quality control records supplied by their vendors for the equipment they prepare (except for such records that code requirements specify the vendor must retain). It is planned that these records be turned over to Philadelphia Electric.

Pertinent audit and surveillance inspection reports, and the documentation of design reviews will be maintained by General Electric-NEBO and Bechtel according to written provisions in their quality control plans.

Bechtel will document site work according to specific requirements contained in applicable specifications and field quality control procedures. These records will be compiled and turned over to Philadelphia Electric at the completion of the project construction.

Philadelphia Electlic will document audits and reviews of specifications, drawings and other technical requirements. j l

The vendor shall have documents which describe his quality control program and organization including administrative _pclicies and procedures affecting quality.

l The vendor shall make available, upon request, h's' i quality control program documentation including the applicable procedures, records, and qualifications governing subsections D.4.1 through D.4.13 for review by General Electric or Bechtel (as appropriate). If concurrence with these documents is required by the purchase order, the vendor shall not start work on a specific task governed by a j procedure until the procedure has been reviewed and comments resolved satisfactorily.

Manufacturing processing, testing, and inspection operations performed by vendors and their subcontractors shall be subject to quality audit or surveillance with respect to the contract work by General Electric or Bechtel, as appropriate. Philadelphia Electric and/or its agent, working through General Electric or Bechtel, shall be accorded access for audit or witness purposes. In this regard, any quality audit or surveillance by General Electric, Bechtel, or Philadelphia Electric l

and/or its agent shall not relieve the vendor or subcontractor of any responsibility for meeting contract requirements.

D.4.15 Audit of the OA Program Surveillance and auditing by the second and third level groups on the l first level will be used to assure that the vendors are complying with specifications, including the NRC QA criteria as invoked in the order.

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1 The following is Bechtel's procedure for assuring that vendors are {

following the NRC QA criteria:

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a. Project Engineering prepares specifications and procurement documents telling the vendor what technical requirements have to be met and requesting that the vendor describe his QA program showing how he will satisfy the NRC QA criteria.

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b. Project Engineering reviews the vendor's program to see that it satisfactorily meets the NRC QA criteria and technical requirements as set forth in the specification.  :
c. The requirements of the vendor's QA program are included in the contractual documents and once the contract is awarded, the vendor accepts responsibility to assure contractual commitments are met including the I

applicable NRC QA criteria and technical requirements. I

d. To assure the vendor's shop practices are meeting the {

i applicable NRC QA criteria and technical requirements, i i

Bechtel Procurement provides surveillance of the l vendors' shops. l The following is General Electric's procedure for assuring that vendors are satisfying the intent of the NRC QA criteria:

a. General Electric, previously and currently, has been  ;

applying appropriate QC plans on vendor supplied l equipment. These QC plans embody the appropriate l l requirements of the NRC QA criteria.

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b. General Electric will provide an audit or surveillance  !

function of its vendors' work to assure that the specified quality requirements are met.

c. Design control activities are documented in formal  ;

General Electric document systems that require vendor compliance with design criteria and submittal of l designs, specifications, and designated vendor i l

procedures to General Electric for review and approval, j Philadelphia Electric audits on a spot check basis the General l Electric-NEBO and Bechtel efforts to ensure vendor compliance with the intent of the NRC QA criteria and similarly audits selected vendors.

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,s . i D.5 GENERAL ELECTRIC QUALITY ASSURANCE PROGRAM The responsibilities of General Electric in this quality assurance program can be summarized as follows. (Also See Section D.3.)

D.5.1 Management l

General Electric-NEBO is responsible for establishing quality control requirements for the equipment within General Electric-NEBO's scope of supply and assuring that such requirements are followed. General Electric-NEBO is also responsible for developing site receipt i inspection storage, and installation requirements for " essential" 1 components under its scope of supply. The prime General Electric-NEBO representative is the Project Manager who is responsible for liaison j with the owner of project quality related matters. The Project Manager is assisted in the accomplishment of the quality task by the following-l

a. The Manager of NEBO Quality Assurance who reports to )

the Vice President and Chief Scientist of NEBO is responsible for integrating the various quality assurance programs within NEBO. The NEBO Quality Assurance is a staff component assigped responsibility for defining intra-division quality-related responsibilities and relationships, for establishing t uniform quality-related procedures and practices at the l Division level, and for integrating, measuring and auditing the quality-related work across the entire spectrum of the BWR business as conducted by NEBO line -

organizations. -

A BWR Quality Council, with the Manager, NEBO Quality Assurance as Chairman, provides for intra-division  !

I communication and integration of quality assurance 1 policies, procedures and practices. The BWR Quality Council consists of representatives from each of the l contributing organizational components of the BWR '

business. The BWR Quality Council normally meets quarterly to review status of the overall quality system, to provide management reports of quality related activities, and to plan future efforts.

b. Managers - Nuclear Fuel and Engineering Services Department, Nuclear Plant Services Department, and Nuclear System Technologies Operation are responsible for establishing overall quality objectives and quality requirements and are also responsible for conducting design control for the overall system design.

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c. Managers - Nuclear Service Quality Assurance (NSQA) are responsible for the quality planning and implementation {

for General Electric-NEBO scope of purchased. equipment, except for General Electric-NEBO manufactured equipment.

d. Manager - Nuclear Fuel and Components Manufacturing Quality Assurance is responsible for the quality planning and implementation for NEBO manufactured products at NEBO facilities in Wilmington, NC.
e. Site Resident Manager is responsible for supplying technical direction for field installation, preoperational testing, and start-up activities on General Electric-NEBO scope of supplied systems and components. Aiding him in some of this effort is a Quality Control Site Representative who reports to the Manager - Quality Control - Site Support, NSQA. l The foregoing organizational relationships are shown on the accompanying Figure D.2.1. --

D.5.2 Preparation of Specifications and Drawings ,

General Electric-NEBO is responsible for the specifications, drawings, and purchase documents for essential equipment within General Electric's scope of supply. These documents and drawings will incorporate applicable design.FSAR commitments, code requirements, and applicable quality control provisions as covered in subsection D.4 l above. ,

In addition, General Electric-NEBO prepares the necessary requirements for the receipt inspection, storage of components at the construction site prior to installation, and for their subsequent handling and installation. The implementation of these site requirements is the responsibility of Bechtel Construction.

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0 LGS D.S.3 Procurement of Equipment All components procured by General Electric-NEBO whether they are manufactured in General Electric facilities or by other manufacturers, I will be subjected to two separate quality programs; one a quality control and inspection program and the other a quality assurance audit or surveillance program. i D.5.3.1 Equipment Manufactured by Other Companies A manufacturer for a given component is selected by General Electric-NEBO on the basis of a determination that_the manufacturer l has the capability to fabricate the component to the desired level of  !

integrity and that he has the necessary experience and an adequate quality control system.

General Electric-NEBO will perform quality assurance surveillance on components and materials procured from such manufacturers to assure that specification and drawing requirements are being met. This effort will be administered by General Electric-NEBO's Nuclear Services Quality Assurance. -

l D.S.3.2 Components Designed and Manufactured by_ General Electric NEBO Departments i To confirm adequate quality system control on components and materials designed and manufactured by General Electric-NEBO Departments, ~.the Manager, NEBO Quality Assurance will conduct quality assurance audits of the quality control programs of those departments.

General Electric will coordinate the retention of quality records for ,

the work they and their subvendors perform under the contractual arrangement with Philadelphia Electric.

D.5.4 Construction Site I General Electric-NEBO Will have a site resident manager located at the i construction site. This resident manager reports to General Electric-NEBO's Project Manager and is responsible for providing I technical assistance to Bechtel Construction for field installation of ,

General Electric supplied equipment and systems. Also located at the {

construction site is a Site Quality Control Representative who reports j to the Manager of General Electric-NEBO's Site Support, Nuclear  !

Services Quality Assurance. This representative is responsible for i monitoring Bechtel to ensure that they are implementing the General j Electric-NEBO quality requirements for receipt inspection, storage, {

handling, and installation of General Electric supplied equipment and j systems. The General Electric-NEBO Site QC representative does not j perform a Second Level Quality Assurance function as defined in l paragraph D.2.2.2. His function is to monitor site activities for '

warranty purposes only. He will report significant discrepancies to Philadelphia Electric and Bechtel through monitoring appropriate channels.

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D.6 BECHTEL QUALITY ASSURANCE PROGRAM Responsibilities of Bechtel in this Quality Assurance Program can be I summarized as follows (see also Section D.3): l The Manager of Quality Assurance is responsible for overall technical l l direction of the Quality Assurance Program, including formulating and '

implementing policy, administration, and coordination of the Nuclear I Quality Assurance Program, and administrative and technical direction of the Project Quality Assurance Engineer thru the cognizant Quality Assurance Manager. The Manager of Quality Assurance is responsible for providing overall coordination of Engineering, Procurement, and l Construction in quality assurance activities to effectively implement l the Quality Assurance Program.

The Quality Assurance Managers, who report to the Manager of Quality l Assurance, are responsible for direct supervision of the Quality Assurance Program, and provide direction to Quality Assurance Engineers. They are responsible to assure coordination of Engineering, Procurement and Construction in Quality Assurance activities to effectively implement the program. Ja addition, they coordinate QAE's review and evaluate Project Quality Assurance Programs, and audit the performance of the various programs. They provide an independent channel for QAE communication to management.

D.6.1 Project Management The Project Manager has responsibility for the surveillance, evaluation, and reporting to San Francisco Management, of the Engineering, Construction and Procurement implementation of the l Project Quality Assurance Program. The Program Quality Assurance l

Engineer directs and controls the Project Quality Assurance Program. l The Project Quality Assurance Engineer coordinates with the Project Manager and assists him by monitoring the quality engineering and quality control functions of the project engineering, construction and procurement activities; he provides the Project Manager with periodic reports of his activities. The Project Quality Assurance Engineer is assigned to the project by and receives technical direction and assistance from the Manager of Quality Assurance through a cognizant l Quality Assurance Manager. Additional Quality Assurance Engineers will be provided when required by the work load.

j D.6.1.1 QA Surveillance of Project Engineering Activities l The Lead Office Quality Assurance Engineer monitors Project Engineering in the implementation of the Quality Assurance Program and reports directly to the Project Quality Assurance Engineer. He may be assisted by Office Quality Assurance Engineers.

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D.6.1.2 QA Surveillance of Construction Site Activities Bechtel Project Management is responsible for monitoring to assure that the quality control requirements for the storage of components and materials, and the installation and construction of the components and systems are effectively implemented. The Lead Site Quality Assurance Engineer assisted by a Staff of Discipline Quality Assurance Engineers is located at the construction site to monitor construction quality control activities and reports directly to the Project Quality Assurance Engineer. The Site Quality Assurance Engineers P.re the field representatives of Project Management and perform the second level quality assurance function at the site. The Quality Assurance Engineers are assigned by, and administratively report to, the Quality Assurance Menager.

The Quality Assurance Engineers perform quality assurance surveillance of field activities including engineering, quality control, and ,

l construction. They review reports of non-conformances, perform surveillance of construction inspection work, and monitor the l implementation of the overall quality control program. )

-- l The Lead Site Quality Assurance Engineer has the authority to stop field work for which Bechtel has direct construction responsibility, and can stop subcontract work through the Project Construction Manager in the event of non-conformance with drawings, specifications, and l procedures for structures, systems, and units on the Q-List. The Quality Assurance Engineers also serve as field contacts for Philadelphia Electric Company's Quality Assurance organization and others concerned with quality assurance in the field.  !

I The reports of the Bechtel Quality Assurance personnel concerning the monitoring of the constructor's quality control effort will be a part of the quality control history file for the plant and will be turned over to Philadelphia Electric upon completion of the plant.

D.6.1.3 Auditing The Quality Assurance Program provides a comprehensive system of Project and Management audits of project engineering activities; field engineering, construction, and quality control inspection activities; and the Procurement activities as they relate to the Limerick Project. l All of the above are carried out, on a sampling basis, periodically, during the design and construction period. At the completion of construction for systems and structures subject to the Quality Assurance Program, a final inspection is performed on the work and associated quality assurance records to assure that necessary inspections and records have been prepared and are on file. A final inspection report is prepared confirming this final examination and audit.

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Bechtel's procedures for conducting and documenting results of management-type QA audits are summarized as follows:

a. General Audits are conducted on an annual basis commencing after award of contract or construction permit. Random unscheduled audits are conducted as conditions warrant or as requested.
b. A general audit plan, including appropriate check lists, is prepared defining areas to be audited. This plan is developed in a preaudit meeting with Project Engineering, Procurement, or Construction, depending on the type of audit, and QA management.
c. An audit review discussion is held with Engineering, Procurement, or Construction, as appropriate, to discuss the findings and obtain scheduled commitments i to complete any necessary corrective action.
d. A report of the general audit noting deficiencies, recommendations and general comments-is prepared and distributed to Management, and to Engineering l Management, Procurement Management or Construction Management, as appropriate, and the' Project Manager. j
e. The responsible Quality Assurance Engineer formally reports, every month to the Quality Assurance l Manager-Audits on the status of items requiring action  !

until all items are closed. 1 D.6.2 Engineering l As plant design contractor for Philadelphia Electric, Bechtel l j

Engineering, through its Project Engineer, is responsible for i establishing quality control and quality assurance requirements for equipment and materials, other than those in the General Electric NSSS scope of supply. This includes preparing or approving detailed j procurement, storage, erection, construction and test specifications  !

and assuring that the design is performed in accordance with the  !

Quality Assurance Program. j The Project Engineer is assisted in the quality effort by Bechtel i Engineering's Chief Engineers of various disciplines who report directly to higher management and as such are not directly a part of the Project Engineering team.

In assisting the Project Engineer, Chief Engineers in the Engineering Department are responsible for reviewing appropriate specifications, drawings, and purchase documents to assure that they include applicable code and quality control requirements as well as FSAR requirements. l 06/22/87 D.6-3

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The Supervisor of Quality Engineering reports to the Manager of Engineering and assists him in carrying out his quality functions for Engineering. The responsibilities of the Supervisor of Quality Engineering include defining and preparing Quality Program procedures i for the Engineering Department, assisting Chief Engineers in establishing standard quality practices for the technical disciplines and assigning and training Quality Engineers. j l

A Project Quality Engineer is assigned to the Project Engineering Team by the Supervisor of Quality Engineering to implement the Quality Engineering Program. Assisting the Project Quality Engineer are Quality Engineers who report to and receive direction from him. The j Project Quality Engineer and the Quality Engineers receive 1 administrative supervision and quality program direction from the l Supervisor of Quality Engineering. The Project Quality Engineer J receives project direction from the Project Engineer. The duties of j the Project Quality Engineer and the Quality Engineers include final l acceptance of Supplier Quality Assurance Programs, participation, as  !

necessary in Supplier Quality Assurance audits, and review of engineering specifications prepared for 0-Listed material, equipment, structures, systems, and components and for servitas affecting the quality of Q-Listed material, equipment, structures, systems and I

components.

Quality Engineering Coordinators (QEC's) are appointed, as necessary by Discipline Group Supervisors to assist Discipline Groups in providing the required coverage in quality engineering program details. QEC's receive direction relating to the quality engineering program from the Project Quality Engineer through the Discipline Group Supervisors.

A Quality Engineering history file for work within Bechtel Engineering's scope of effort will be maintained by Bechtel. This file will be transferred to Philadelphia Electric at the completion of i the plant. l l

D.6.2.1 Preparation of Specifications and Drawings Engineering is responsible for preparing specifications for Q-Listed equipment (except for the nuclear components supplied by General Electric). It is also responsible for preparing construction l specifications, drawings, and project installation requirements.

These documents and drawings will-incorporate applicable design, FSAR, l and code requirements, and quality assurance provisions.

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  • wq D.6.2.2 Procurement Activities With the exception of the Nuclear Steam Supply Systes, Philadelphia Electric or Bechtel will purchase Q-Listed equipment and material to specifications and drawings prepared by Bechtel or E%o Engineering.

A manufacturer for a given component will be approved -by Philadelphia Electric only after Bechtel has ascertained the manufacturer's capability to fabricated the component to the desired level of quality and has determined that he has an adequate quality control capability.

Once a manufacturer is selected, Bechtel will perform quality l assurance surveillance on components and materials procured from such manufacturers to assure compliance with specification requirements.

D.6.3 Procurement Bechtel Procurement has the responsibility to perform a quality l assurance surveillance function for Philadelphia Electric on the procurement of purchased items which are outside of General Electric l NSSS scope of supply. Bechtel Engineering and Philadelphia Electric have the primary responsibility for vendor evaluation and selection.

Some of the contracts for procurement of such components are processed under Philadelphia Electric purchase orders and others are processed under Bechtel purchase orders. Regardless of whether a Philadelphia l Electric or Bechtel purchase order is used, Bechtef Procurement still performs the quality assurance surveillance function to assure that equipment manufacture is in compliance with applicable specifications.

Bechtel Procurement Supplier Quality carries out the surveillance f function utilizing established guidelines and procedures. Check-off lists describing the specific areas which should be monitored will normally be employed. These check-off lists represent the minimum amount of surveillance that must be performed. Depending upon the circumstances, the Bechtel surveillance personnel, at their discretion, may do more and will report on the additional surveillance performed. Where necessary Bechtel Engineering personnel assist 1

Bechtel Procurement in performing the surveillance effort.

j D.6.4 Construction l

Bechtel Construction through its Project Construction Manager is l responsible for construction of the plant to approved engineering specifications, drawings and procedures. The Project Construction Manager has the prime authority and responsibility for Construction, Construction Engineering and Subcontractor activities in the field.

Site construction procedures may be prepared to supplement Construction and Engineering direction for activities affecting l quality for 0-Listed equipment. Such procedures will be reviewed and I

approved by Bechtel Construction.

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The Project Construction Engineer is responsible to the Project l Construction Manager for supervision of construction engineering activities at the jobsite. In performing this function, he assigns qualified Construction Engineers through the associated Lead Discipline Construction Engineer within each discipline to provide engineering direction and monitor construction activities. The Project Construction Engineer is responsible for the accuracy and completeness of engineering documentation, ascertaining that work is properly performed, and that defects are removed and repairs are carried out in accordance with the applicable codes, engineering drawings, project specifications, and quality control procedures. He maintains liaison with project design engineers.

The Discipline Construction Engineers report through the Lead Discipline Construction Engineers to the Project Construction Engineer. They receive technical direction from the respective Lead Discipline Engineers for construction engineering functions. l The Chief Construction Quality Control Engineer supervises the Construction Department Quality Control Program and reports to the Manager of Construction. He is responsible for technical direction l and administration of Construction Quality Control Engineers. The Chief Construction Quality Control Engineer is assisted by the Quality

' l Control Supervisor (s).

The Project Construction Quality Control Supervisor for Limerick l reports directly to the Chief Construction Quality Control Engineer.

He coordinates quality control activities with engineering and construction personnel. He also provides technical support and monitors the performance of the Project Construction Quality Control Engineer.

l The Project Construction Quality Control Engineer (PCQCE) reports  !

through the Quality Control Supervisor to the Chief Construction I Quality Control Engineer. The PCOCE supervises the quality control l and inspection functions and sees that the quality of the work is properly inspected and documented. The PCOCE provides direction and supervision of testing laboratories and is responsible for the maintenance and safeguarding of the field quality files.

The PCOCE has authority to stop work. This authority, exercised through the Project Construction Manager, shall require immediate cessation of work operations or construction activities determined to be improperly controlled and where corrective action would be extensive or may not be fully effective. He shall assign personnel to establish and maintain the system to control measuring and test equipment.

06/22/87 D.6-6

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  1. 0 A The Quality Control Engineers and Technicians report to the PCQCE.

They are responsible for preparing Inspection Plans in accordance with the Field Inspection /QC Notices Manual, performing Quality Control inspections including final acceptance of the work, initiating and processing of Nonconformance Reports and performing overall construction surveillance including material control. Procedures used to control and perform inspections by Quality Control Engineers and Technicians will be reviewed and approved by Philadelphia Electric Company.

When site construction work is subcontracted the Project Construction Quality Control Engineer (PCQCE) performs the quality control surveillance function on such site subcontractor's work.

A quality control file maintained for Bechtel work will be available for Philadelphia Electric review. At the completion of the job, it will be turned over to Philadelphia Electric for their quality control history file of the plant.

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r LGS e av e D.7 DESIGN CONTROL D.7.1 Philadelphia Electric Company The basic responsibility for design control has been assigned to Bechtel and General Electric-NEBO for work in their specific areas of responsibility. Design reviews are performed internally with

! experienced personnel not directly associated with the original design effort.

In addition, Philadelphia Electric will, through its Director, Quality Assurance Division audit the design efforts of General Electric-NEBO and Bechtel to assure that they are in fact operating in accordance with an adequate design control system.

The Philadelphia Electric design review effort includes the review and approval of the FSAR to assure it establishes proper design criteria and provides an adequate design description of the plant. The design review performed by Philadelphia Electric also includes the review of specifications and appropriate back-up information to assure that the pertinent codes, standards, FSAR requirements and -quality requirements have been incorporated. Specifications will be reviewed by Philadelphia Electric Engineering and Research engineers and versonnel of Nuclear Operations, as appropriate, to ensure compatibility between components and systems, adequacy of material selections, acceptability of installation, access and maintenance requirements, and evaluation of special design provisions or requirements. Written comments are returned by Philadelphia Electric to the Ganeral Electric-NEBO Project Manager or the Bechtel Project Engineer.

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This review will include but not be limited to: the reactor coolant system and its directly associated auxiliary systems, the containment system, the engineered safety features, the fuel handling system, the radioactive waste disposal system and plant accessibility for maintenance and inspection.

Unresolved interface questions between contractors would be resolved by participation of Philadelphia Electric.

D.7.2 General Electric Nuclear Energy Business Operation The General Electric Nuclear Energy Business Operation (General Electric-NEBO) has contracted for the design, manufacture and delivery of the Nuclear Steam Supply System as defined by contract. As part of this work, General Electric-NEBO has an internal design control program covering work within its scope of responsibility. Design l review is carried out by individuals not involved directly with the original design work.

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For equipment procured by General Electric-NEBO for which it does not have the lead design responsibility, General Electric-NEBO will review and audit its subcontractors' design efforts with a frequency and depth consistent with the application of their equipment.

Among the items included in the General Electric-NEBO design control I

effort are the following:

a. Determine that the required design bases, FSAR commitments and other regulatory requirements are incorporated properly into the design drawings, specifications, and pertinent procedures and instructions.
b. Independently review to verify the adequacy of the design of equipment and systems provided by General Electric-NEBO through review of drawings and l specifications.
c. Identify required acceptance criteria for test and inspection. --
d. Assure that the design and support data for nuclear related portions of the plant under General Electric-NEBO cognizance are accurately described in the FSAR submittals. {

D.7.3 Bechtel l 4 Bechtel as architect engineer for this project has the responsibility l for the design and related procurement effort for components and equipment within its scope of responsibility.

As part of this work, Bechtel Engineering has an internal design control program covering work within its scope of responsibility.

Design review is carried out by individuals not involved directly with the original design work.

For equipment procured by Bechtel for which it does not have the lead design responsibility, Bechtel will review and audit its subcontractor's design efforts with a frequency and depth consistent with the application of the equipment.

Among the items included in the Bechtel Engineering design control effort are the following:

a. Determine that the required design bases, FSAR commitments and other regulatory requirements are incorporated properly into the design drawings, specifications, and pertinent procedures and instructions.

06/22/87 D.7-2

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b. Independently review to verify the adequacy of Bechtel designed structures and systems through review of associated calculations, drawings, and specifications. i This would include such areas as stress and thermal design analyses, material compatibility, seismic analysis and design interfaces.
c. Assure'that :he equipment systems are accessible for maintenance epair, and in-service inspection. i l
d. Identify rr %d acceptance criteria for test and I inspectic,;.
e. Assure that the design and support data for nuclear related portions of the plant under Bechtel cognizance are accurately described in the FSAR submittals.

I Bechtel has a formalized program used in the design control activities under its responsibility.

D.7.4 Engineering and Design Consultants --

Philadelphia Electric will utilize the capabilities of design and j engineering consultants to provide design review in specialized areas. I

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06/22/87 D.7-3

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.(  !.FIELO DA HAS LINES OF QUALITY AS*MANCE SURVEILLANCE A3 "

AND/C74 AUDITINO TO ALL GROUPS SHOWN.

g 2.PROCUR& TENT OF COMPONEN7S AND MATERIALS OUTSIDE OF

' i g G.E.'S SCOPE OF SUPPLY. THIS PROCU";rMENT GROUP USES u

SPECIFICATIONS GENERATCD fW BECHiEL ENGINEERING FOR

] itE PROCUREMENT EFFORT.

d 3. THE LINES OF QUALITY ASSURANCE AUDITING ANO

" ' y? St#tVE!LLANCE INTO THE PROJECT CONSTRUCTION Q.C. ENGINEER

'es AttE TO INDICATE THAT SUCH AUD] TING AND SURVEILLANCE IS TO COVER ALL AREAS OF BECHTEL'S SITE QUALIT Y 4

  • CONTROL AND INSPECTION PROGRAM WHICH IS UNDER THE OVERALL SURVE!LLANCE OF THE G.C. ENGINEER.

s p j. jg i) EXAMPLES OF SUCH ARE TESTING L LABORATORIES EFFORT.

FIELD INSPECTION EFFORT,1NSPECTION OF WELDING EFFORT.

h j9 4. NEBO MANAGER OF QUALIT Y ASSURANCE HAS LINES wa i - 4' $

OF QUALITY POLICY COMMUNIC ATION AND AUO!T TO ALL

.f yf" .

GENERAL ELECTRIC ORGAN 12ATIONS SHOWN.

Of[$,M m.4 5. MONITOR SITE ACTIVITIES CONCERNING G.E. SUPPLIE0 EQUIPMENT AND SYSTEM FOR WARRANTY PURPOSES ONLY.

6.FOR THOSE CASES THAT BECHTEL CONSTRUCTION kji c' ,

SUBCONTRACTS SITE CONSTRUCTION WORK

- od (E.G. THE CONTAINMENT VESSEU SEE Af'j..

N-SECTION D.2.2.10F THE

SUMMARY

DESCRIPTION OF THE Q.A. PitOGRAM.

'; hr  ! 7. LINES OF ROUTINE G.A. COMMUNICATIONS Ex!ST BETWEEN g I THE P.E.CO. PROJECT M ANAGER. G.E. PROJECT AND FULL PROJECT MANAGERS AND THE BECHTEL PROJECT g ENGINEER.

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8. PERFORMS 2ND LEVEL SURVL ALLANCE OF SITE RPV F ABRICATION ONLY.
9. NSSS AND FUEL PROJECT MANAGER HAVE LINES OF COMMUNICATION AND INSTRUCTION TO THE ENGINEERING.

MANUF ACTURING ANO OUALITY ASSURANCE GROUPS INVOLVED WITH THE PRODUCTS AND SERV!CE IN THEIR SCOPE OF SUPPLY.

L EGEntn LINES OF RESPONSialLITY

- - - - - - - - LINES OF AUO!T AND/OR SURVEILLANCE

- - - - - - - - - LINES OF QUALITY ASSURANCE SURVEILLANCE  !

ANor0R At.o!T ,

LINES OF DIRECTION AND CONTROL a a a LINES OF COORDINATION O O O LINES OF ADMINISTRATION PROJECT REPORTING RELATIONSHIP 1 DIRECT ACCESS TO NCB0 VICE PRESIDENT

.' !.' : ~~;;;;;; ;7 PROJECT RCPURTING RELATIONSH;P l

' _ _ _i _ PERSONNEL s ' LOCATED AT CONSTRUCTION SITE X X X X PECO PROJECT OIRECTION 1

i _ _ _l _ _ _ , ,____!____

I swemnitND[NTS

,m- MULEM i___ ____i i________

' surtmNETDENTS '

i_________.

JUNE,1987 i____l---

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PHILADELPHIA ELECTRIC COMPANY

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i - sM"" ' '- ------ LIMERICK GENERATING STATION UNIT 2 A PREL]M] NARY SAFETY ANALYSIS REPORT l l QU. ALIT Y, _ASSUR ANCE PROG, RAM c'"  !

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