ML20237E131
| ML20237E131 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 08/24/1998 |
| From: | Jeffery Wood CENTERIOR ENERGY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 2483, NUDOCS 9808280269 | |
| Download: ML20237E131 (18) | |
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Daws-Besse Nuclear Power Station gn 5501 North State Route 2 m
Oak Harbor Ohio 43449-9760 f 0
. John K. Wood 419u249-2300 Vice President - Nuclear Fax: 419-3218337 Docket Number 50-346 License Number NPF-3 Serial Number 2483 August 24 -1998 United States Nuclear Regulatory Commission Document Control Desk Washington, D. C. 20555-0001
Subject:
Request for NRC Approval of Reduction-In-Commitment Changes in the Quality Assurance Program Material Receipt Inspection Process and Responsibilities Ladies and Gentlemen:
)
- This letter provides proposed reduction-in-commitment changes to Davis-Besse Nuclear Power l
Station's (DBNPS), Unit 1 Updated Safety Analysis Report (USAR) Chapter 17.2," Quality Assurance During the Operations Phase,"(Quality Assurance Program). Pursuant to 10 CFR 50.54(a)(3), Toledo Edison (TE) hereby submits its plans regarding changes in the material l
receipt inspection process and responsibilities at the DBNPS, Unit 1.
Although these modifications, as discussed in detail in the attached 10CFR50.54(a) review, have been identified as reductions-in-commitment, the Quality Assurance (QA) Program continues to satisfy the criteria of 10CFR50,-Appendix B, because the changes alter commitments that are not regulatory requirements.
I Toledo Edison requests that the NRC approve these proposed changes to the DBNPS Quality Assurance Program within the next 60 days in accordance with 10 CFR 50.54(a)(3)(iv). These l
proposed modifications in the material receipt inspection process transfer responsibilities to an area other than a traditional Quality Assurance / Quality Control organization. This philosophy is similar to receipt inspection changes approved by the NRC for the Peach Bottom Atomic Power j
Station and Limerick Generating Station (NRC TAC NO. U00806, QA 94-09), and for the Duane j
Arnold Energy Center (NRC Region III letter, dated December 20,1995).
1 9908280269 990824i_. _.
1 PDR ADOCK 05000346 P
PDR I
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i, Docket Number 50-346 Lic:nse Number NPF-3 Serial Number 2483
.Page 2,
If you have any questions regarding this submittal, please contact Mr. James L. Freels, Manager -
Regulatory Affairs, at (419) 321-8466.
Very truly yours, i
JCS/laj
' Attachments cc:
A. B. Beach, Regional Administrator, NRC Region III S. J. Campbell, DB-1 NRC Senior Resident Inspector A. G. Hansen, DB-1 NRC/NRR Project Manager i
Utility Radiological Safety Board l
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Docket Number 50-346 License Number NPF-3 Serial Number 2483 Page1 ATTACHMENT 1 D.iVIS-BESSE NUCLEAR POWER STATION USAR SECTION 17.2, " QUALITY ASSURANCE DURING THE OPERATIONS PHASE" CONTENT AFFECTED BY PROPOSED CHANGES l
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t Docket Numbec 50-346 '
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~ License Number NPF-3 Serial Number 2483
.1 Attach, ment 1 Page 2 1
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l, Note 1
The reduction modifications proposed in this submittal are typed, bolded, underlined and j
ballooned on the attached marked-up USAR pages.
The attached marked-up pages of USAR Section 17.2 also include several non-reduction changes made prior to the changes proposed by this submittal. These non-reduction changes are I
handwritten and identified in boxes to differentiate them from the reduction modifications i
proposed in this submittal and for which NRC approval is being requested.
']
The purpose of these non~ reduction changes was the reorganization of the procurement
)
engineering function including transferring its reporting from Davis-Besse Supply to Design Basis Engineering. These non-reduction changes are not discussed in this submittal (i.e., the 10 CFR 50.54 evaluation). The non-reduction change have been included to promote a thorough 1
- understanding of the design engineering, procurement engiiteering and receipt inspection
~i functions that would result from the NRC's approval of the proposed modifications to the receipt
. inspection process.
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Docket Number 50-346 License Number NPF-3 Serial Number 2483 Page 3 '
- D-B FRESIDENTn tNCR GENERATION GROUP 20 P
The President - Power Generation Group report s to the Chairman, President ed Chief Executive Officer and is responsible for directing the operation of gli CEC /CSC power stdions.
SENIOR VICE PRESIDENT - NUCLEAR 18 The Senior Vice President. Nuclear reports to the President - hvet 20 Generation Oroup.and is responsible for directing the operation of the Davis-Besse Nuclear Power Station.
VICE PRESIDENT - NUCLEAR.e D/ MIS-BESSE la The Vice President - Nuclear reports directly to the Senior Vice PresiQnt 18
- Nuclesr and is responsible for kil matters relating to the engineering, desip. operations, maintestance and modification of the Davis-Besse Nuclear h
Power Station. The Vice Presidens - Nuclear exercites responsibility over 14 the Toledo Edison Nr: lear Group. He reserves the authority to conduct or order the auditing of any activity t.t any time to deterigfue compliance to 1
the requirements specdfied in the Welear Quality AssurSnce Manual (NQAM).
He is responsible for final approval of the Wclear Quality Assurance Manual 19 (NQAM) and c.he ASME Quality Assurance Manual (AQAM) and is airo responsible for conducting continual review of the e rerall effectiveness of the Quality 20 Assurance Program.
5
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17.2.1.4 Toledo Edison Nuclear Group 18 i
_ DIRECTOR - NUCLEAR ASSURANCE i.
The Director - Nuclear Assurance reports i.o the Vice President - Nuclear.
20 He is authoriz d to identify quality problems 3 initiate recomcud os provide 19 solttiloas, through designated channels; and verify tophmentatica of solutions. Conditions adverss to gutlity that appear to werrant s;tspension of resctor operation, including startup or power generation are imediately i
reported to the Plant Manager. The Director.- Naclt cr Assurance is respm sible for the development, maintenance and approval of the Nuclear Quality Assurance Manual (NQAM) and the ASME Quality Assurance Manubl (AQAM) as thcir sponoor. 7he Director - hoclear M surance is responsible for i
adequate staffing of the Nu-lear Assurance Department. The Director is
-responsible for managing the activities of independent safety engineering, and the review of external information and plant operations apsessa.cnts.
The Director - Nuclear Assurarne ir responsible for managing support cervices associeted with procedural control, recorts manageracnt and document control.
and coordinating support survices requested from (,he Centerior Service 20 Company. The Director - Nuclear Asaurance is responsible for nuclear training and providing dir:ction for the Nuclear Training Prograt-to support 19 the nnds of site personnel in accordance with laws, regulations, standards l
and comitronts. The Directoro Nuclear Assurance is also reshnsible for I
security to ensure the security requirements are maintained in accordance with the Industrin1 Security Plan.
INFORMATION ONLY 17.2-4 REV 29 12/96 j
)
i Docket Number 50-346 i
License Number NPF-3 Serial Number 2483
, Attachment 1 Page 4 -
MANAGER - NUCLEAR SAFETY AND INSPECTION 19 9
The Manager - Nuclear Safety & Inspection reports to the Director - Nuclear 19 Assurance and is responsible for managing the Nuclear Safety & Inspection staff in the quality review, inspection, and examination of plant structures, 14 systems, and components within the scope of the Nuclear Quality Assurance Program to assure compliance to procedural, drawing, and engineering specification requirements. This responsibility includes the inspection of welding tu verify it meets ASME, National Board, and State of Ohio requirements in addition to coordinating the activities of the Authorized 1
Inspection Agency to ensure Code compliance. The Manager - Nuclear Safety &
19 Inspection is also responsible for development and maintenance of the Nuclear Safety & Inspection and selected Nuclear Assurance Department Procedures and review and approval of the ASME Quality Assurance Manual (AQAM) to verify it meets ASME, National Board, and State of Ohio requirements. The Manager - Nuclear Safety & Inspection is also responsible for review of all corrective action docunients for cipma_-nue _ review and approval or_c eu rence 20
_with_ select site proceduresm E :ipt in:p:;tir;d. ' _:n'nr:ne:in;;;;; ;;d (y: ib d A;E :dli:] '; hen.t:linn And Nuclear SafetyTIris[ection 19 1
Stef f training.dThe Manager - Nuclear Safety & Inspection is also responsible ic'r directing the activities of the independent safety 18 engineering grot p in providing technical expertise onsite to allow for l
systematic and J ndependcut assessment of plant activities, surveillance of
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plant operations and maintenance activities to provide independent technical 4
verification tha t these activities are performed correctly, and investigation of pKant incideito which may affect the underlying assumptions in the USAR Accident Analys.c. The Manager - Nuclear Safety & Inspection is also 19 reyonsible for the review of all external information received in support of improved performance and reliability and for plant operations assessments.
18 The Maonger-Nut lear Safety and Inspection is responsible for coordinating 20 inspection and aramination services provided by the Centerior Service Company.
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plant
& i,giso responsible for receipt inspections. source
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t ingnections a_nd review of vendor sur,Dlied documentation s
asocia,tsd with nuclear fuel and radioactive waste.
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HANAGER - t)UA147Y ASSESSqH_T, a
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The Manager - Quality Asse6sment teports to the Director - Nuci ar Assurance.
19 but is authorized direct access to the Vice President - Nuclear or higher Corporate management for qualicy assurance matters if such a need exists.
l The Manager - Quality Assessment is free of non-QA rElated duties. He is in(ependent from tost and scheduling considerations when opposed to safety l
considerations. He has the authority and organizational freedom necessary to adequately fulfill assigned responsibilities. The Manager - Quality Assess.
l ment is responsible for essuring and advising the Plant Manager and Vice 20 l'
President-Nuclear of the adequacy and effectiveness of implementation of the i
l-approved Nucleer Qaality Assurance Progre.m. He is responsible for review 19 1
and approval of the Nuclear Quality Assurance Manual to verify it meets l
codes, standards, and regulatory Commitments. He also has the resp 0nsibility and authority for the interpretation of the Nuclear Qaality Assurance Manual
' requirements, and codes, standards and regulatory ceranitnents as they pertain to quality assurance requirements. The Manager - Quality Assessment has the authority to identify goality problemst initiate, recommend, or provide solutions, through designated channels verify implementation of solutions; and verify conformance to established quality requirements. The Manager -
Quality Assessment has the responsibility and authority to suspend l
17.2-5 REV 20 12/96 l
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' q Docket Number 50-346 i
- License Number NPF-3 l
Serial Number 2483
' Attachment 1
' Page 5' '
D-B
' DIRECTOR - ENGINEERING AND SERVICES 19-The' Director - Engineering and Services reports directly to the Vice President - Nuclear.and is responsible for all engineering activities in
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support of design control, plant modifications, and system performance
. requirements for Davis-Besse Nuclear Power Station. The Director -
. Engineering and Services is responsible for directing all phases of inter.
20 action. relating to regulating agencies to ensure compliance with laws, 19 regulations, and commitments. His responsibilities also include direction for Emergency Preparedness. Program, Environmental Compliance Program, Land Industrial Safety Program. The Director - Engineering and. Services is
< responsible for purchasing and materials management activities, including-20 coordination of support services provided by the Centerior Service Company.
His responsibilities also include activities associated with budget and 19 cost control, and nuclear projects. The Director - Engineering and Services
-is also responsible for the budget, administration, procedure control. and training within the Engineering and Services Department.
MANAGER - DESIGN BASIS ENGINEERING 20 The Manager - Design Basis Engineering reports to the Director - Engineering
-and Services and is responsible for. managing and coordinating Davis-Besse modification' engineering, and associated safety evaluations to assure safe designs and continued conformance to design requirements. This includes the maintenance of design drawings, specifications and. calculations. He is responsible for functions relating to: reliability and risk assessment's nuclear reactor analysis: nuclear safety analysis: simulator engineering reactor engineering: nuclear fuel procurement. performance and design:
reactor refuelings ese core physics testing He is also responsible for i
installation, improvements and maintenance af plant computer monitoring, l
computer' aided engineering systems, and coordinating nuclear fuel procurement j
aand computer related. services provided by tme Centerior Service Company.
MANAGER - PLANT ENGINEERING The Manager -' Plant Engineering reports to t,he Director - Engineering and Services and is responsible for minimizing Davis-Besse forced outages and lost capacity by providing engineering services to ensure proper installation, operation, preventive maintensnee, testing, and problem resolution for uptimum system performance and reliability. He is responsible for providing direct day-to-day engineering support in the areas of plant l
I thermal. performance monitoring: in-service inspection and testing
-l modification testing and special. testing predictive maintenance: evaluation I'
of plant chemistry' and radiochemistry issues: and special engineering l
projects. Additional responsibilities include engineering support to address j
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non-routine technical issues related to the operation and. maintenance of Davis-Besse, and maintenance of,the Fire Hazards Analysis Report (FHAR).
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ci d proc witvnt h e nc W e n ?_a_fincludm.
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r*** Mand source laspection.
r-a-:=* InsDeetions. source inspections. an~direEew of vendor i
sunolied do_gumentation (except for nuclear fuel and i
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radioactive wastek
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17.2-8 REV 20 12/96
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Docket Number 50-346 License Number NPF-3 Serial Number 2483 OP"""
INFORMATION ONLY D-B be performed under the most adverse design conditions as determined by analysis.
When alternate calculations are performed to verify the correctness of the original calculations, they include provisions for verifying the appropriateness of assumptions, input data, and code or other calculation 5
method used. The alternate method when used is required to provide results which are consistent with the original calculation or analysis, i
17.2.3.5 Design Package Review i
f Prior to release, the completed design package is reviewed by Nuclear 5
l Group Departments affected by the" design. All review comments are document-8 ed and resolved, and in addition, analyzed for potential impact on safety 5
evaluations and design verifications.
18 17.2.4 PROCUREENT DOCUMENT CONTROL.
5 17.2.4.1 General The procurement of materials components, equipment, consumables, spare and replacement parts, services, etc.. necessary for plant operation.
5 refueling, maintenance, and modification are controlled in accordance with approved procedures. These procedures specify measures that describe the l14 process for the preparation and control of procurement documents, control l8 of supplier and contractor performance, source evaluation and selection, source verification, receiving inspection and testing, and item or service 5
acceptance. The requirements of ANSI N65.2.13 and ANSI N45.2.2 are incorporated into their procedures whenever the requirements are applicable.
Expeditious procurement activities are defined in procedures to support 10 unanticipated requirements. These procedures contain provisions for material traceability and controls to prevent the declaration of operability of the i
system until such time that the activity and documentation requirements 5
specified in the approved procurement document have been completed or evaluated by Davis-Besse Supply for operability.
l20 The procurement of spare or replacement parts for structures, systems and components within the scope of the Nuclear Quality Assurance Program are 5
subject to requirements equal to or greater than the original requirements.
17.2-21 REV 20 12/96
I)ocket r4unaber 50-346 License lVtunbcr NPF-3 Sedal ?4uniber 2483 fl,*"*""
INFORMATION ONLY D-B Huclear fuel is procured through the use of formal contracts signed by an 20 officer of CSC. An individual has been designated by the Plant Manager as the ' Fuel Custodian" and acts in the capacity of the Manager-Davis-Besse Supply for the procurement of nuclear fuel under the responsibility of the Managec-Nuclear Engineering.
Davis-Besse Supply performs technical evaluations of items purchased 20 commercial grade that are to be used in Nuclear Safety Related applications to assure the items will perform their intended safety functions.
Procedures developed by Davis-Besse Supply describe the commercial grade dedication process including the following elements:
a.
The methods for determining if a basic component as defined in 5
10CFR21, can be upgraded or purchased as commercial grade and 5
dedicated for NSR application, 9
b.
The criteria for identifying the critical characteristics by analy-sis, including the methods for verifying that the characteristics are controlled by the manufacturers.
c.
The criteria and methods for identifying the critical characteristics 5
that are essential for the items purpose and function under the most severe operating conditions that the item will be subjected.
d.
The criteria for determining the type and depth of product acceptance and for determining the " Point of Dedication *'at which time Centerior 14 Service Company assumes the responsibility for 10CFR21 deportability requirements.
5 17.2.4.2 Procurement Documents All materials and contracted services provided for Davis-Besse are authorized l14 by an approved procurement document.
Procurement documents either contain a description of the technical and quality requirements for the item or service, or reference engineering specif3 cations which contain these requirements. The procurement docu-ments include provisions for the following, as applicable A description of the scope of work to be performed by the supplier.
a.
b.
Reference or inclusion of the applicable regulatory requirements, 5
design basis, ASHE codes, and other industry standards.
c.
Inclusion or reference of basic technical requirements including drawings, specifications, quality requirements, and special instructions and requirements for designing, f abricating, cleaning, erecting, packaging, handling, shipping, storage and inspection. References are 'dentified by titles and revision.
d.
Requirements for the supplier to have a documented quality assurance program to the extent specified in the Purchase Order as appropriate to the items or services being procured.
l1 e.
Requirement for extending applicable requirements of the procurement 5
documents to the supplier's lower-tier suppliers.
l 17.2-72 REV 20 12/96 l
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Docket Number 50-346 License Number NPF-3 Serial Number 2483
. Attachment 1 Page 8 -
D-B l
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Identification of documents to be prepared, maintained, submitted, or made available for review and/or approval, such as drawings, specifications, procedures, sub-supplier procurement documents, manufacturing and inspection plans, inspection and test records, 5
personnel and procedure qualifications, and material chemical and physical test results.
g.
Provisions for CSC right-of-access to the suppliers' facilities and 14 records for audits and source inspection.
5 h.
Requirement for reporting and approval for disposition of nonconform-ing items and adherence to 10CFR21 requirements._-
20 and hold / witness points; and that the supplier is i
included on a listing of approved vendors.
2 17.2.4.3 Procurement Document Reviev
'l5 Procurement documents are prepared by a procurement engineer and reviewi d by 16 a separate engineer knowledgeable of technical and quali_ty requirements prior to superv_isor approval and award to a suppliepa...... -....:;;
- .".m 18 k6 D ~ ~ t i t '--ill i!? : '::-fi 92 E:1::f:5 ;;d:r;;;;; rer:r_- ::: includin; ti :::
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csanges to thE m an cal and quality requirements, including supplier selection, are subject to the same degree of review as the original procurement document.
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Review and approval by,',Deri: 5:::: S ;;17 assures that the technical l29 and quality requirements are sufficient, clear and adequately stated can be t'
inspected and controlled; and include adequate accept / reject criterig These requirements include regulatory, administrative and reporting requirements:
specifications; codes and industrial standards: test and inspection require-ments, and special process instructions that must be complied with by suppliers.
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20 T'e -a tiple re-1:1 cenduct:d by D:ri: 5::::
7 rpplierbie t's " :10 : A::ur:::: M p:: ::::, ::: p::f:;.;d :: :::::: th:t ge:11ty requir:- nte ::: : ffici::t, :1::: : d ;d:q :::!y :::t;d, 5
in:p :t:5111ty ::quir ::::: ::; ::ti:fi:d. h:14 ;; ;itz.;;; p;ir.;; cr;
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- ptf reject :!teri: ::: inclue:d; th: :h::hli:t p;;p;r;d tj-8 d
I Devi-Fe se Supply 2:: 1.:1 d:d.h:t d:::rit;; th :h;;;;;;ri: tic; 20 ftebe inrpected et ::::Irin; in:p;;ti:n, :.d th:t th; ;;,pplic; i; ir. lud;d 5
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17.2.4.4 Supplier Selection Prior to award, potential suppliers are evaluated to determine their ability to supply items or services in accordance with the requirements of pro-5 curement documents. The evaluation also includes a technical evaluation, which may include direct evaluation of the suppliers: facilities'and i
I
_ p_e_rsonnel as described in 17.2.7.
l Procurement doc - tm include criteria prepared procurement engineers that describe the y
characteristics to be inspected at receipt in:pection.
$17.2-23 REV 20 12/96 M-
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l Docket Number 50-346 l
License Number NPF-3 Serial Number 2483
. Attachment 1 INFORMATION ONLY 17.2.6.4 Restricted Documents l5 Departments with the..siceibility for the initiation or use of Safeguard 8
documents, have procedures that describe the handling and processing of 5
these documents. These procedures incorporate the requirements specified 5
in the HQAM under Document Control and provide the additional controls 9
l specified in the HQAM section entitled Industrial Security.
9 10 9
17.2.7 CONTROL OF PURCHASED MATERIAL, EQUIPMENT AND SERVICES 17.2.7.1 Supplier Selection Potential suppliers or contractors are evaluated prior to contract award to determine their ability to supply the required items or services. An assessment of the suppliers' Quality Assurance Program is performed based on any or all of the following:
a.
Review and evaluation of the supplier's current quality records supported by qualitative and quantitative information which can be objectively evaluated.
5 b.
Evaluation of the supplier's history of providing items or services which perform satisfactorily in actual use.
c.
Verification of the supplier's technical and quality capability as determined by direct evaluation of this facilities and personnel, and the implementation of his quality assurance program.
3 d.
Verification that the supplier is a holder of a current ASP 2 Certifi-cate of Authorization or Quality Systems Certificate, or a National Board Certificate Holder whose scope is consistent with the item /
services to be procured.
Suppliers considered acceptable are placed on an Approved Vendors 7
e.
List. Th Manager-Quality Assessment is responsible for controlling and 20 maintaining suppliers on this list using the results from periodic evaluations, source surveillance / audits, receiving inspection reviews, and operational performance reviews.
17.2-27 REV 20 12/96
Docket Number 50-346 License Number NPF-3 Serial Number 2483 Page 10 J
D-B Desiere Basis Engineering and 17.2.7.2 Source Verification l5 I EnMna <<ing i e __ - -
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- ri: 5:::: E pply-has the responsibi lity for recommending those items, 20 or services for which source verifica
- lon activities are required. Normally.
5 source verification is required when
- he quality characteristics would be 5
difficult to verify after receipt, items are vital to plant safety for it.ms 5
i whose design, manufacture, or test is complex.
9 Frocedures have been developed by 4he0 Nuclear Assurance D:;::t :nt that l18 describe the criteria for determining the tyne of verification required l9 h e.h M ' during fabrication, inspection, testing and shipping at the vendor's facility, 5
] methods fo o
r e
is on n
r ur me document requ e-5 mente __
ee: :::i.i:::i:n ::ti:n h th: M :1:::..::nr:n : _:p :tn:n; :.:h _:
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7_g::;[n hat procurement document requirb: '- ir-11' nt:. -Mii:, ::::::
performe ing ::ti:n :n' ::
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.s ve been satisfied.
Special verification requirements are established and included in procurement 5
documents for consnercial *of f-the-shelf" items where specific quality assurance controls appropriate to nuclear operations cannot be imo_osed in a e practical manner.
{ ' ' 'ipt inspection rece i
17.2.7.3 Accel,.ance of Materials and Items l
Items _ ou_rchandloruse in quality related applications are procNsed throughh 5
C:lii_. M p.: $ctI 2) prior to storage, installation or use.
The receiving inspection Is performed iri accordance to approved procedures, utilizing an inspection i:hecklist and associated procurement documents. The inspection methods include verification of source inspection, shipment damage, 9
dimensional inspection, testing, vendor supplied document review, material 5
identification, or a combination thereof as applicable.
9 When specified, supplier furnished documentary evidence that items conform to procurement requirements is required to be available prior to release 9
of materials or items for use. This documentation identifies the specific requirements such as applicable codes, standards, or specifications, and any accepted deviations. An item is maintained in a hold status _until._.__
j.16_
- quality documentation has been evaluated as acceptable.
p'eslen Basis EngineerinEnd The methods used for verifying the validity of Certificates o Confor-'
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mance, certificates of Compliance or material physical or chemical analysisreportsareidentifiedbypNuclearAssuranceDepartmentprocedures.
18 9
Upon completion of_rt.ceivimg inspection activities, accepted items are identified.Q;- fr,'i Qand released by Huclear Assurance to p
18 Davis-Besse Supply for storage or issue.
20 l
Items det. ermined to be non-conforming upon completion of the receipt l16 0'"*:r'$U'H'""'"""*"'""'""""'"' '" " m esien Basis Eneineerine or (e.e.. Accept Tae) 1
,w -
7,2-28 REV 20 12/96 Source verification action by Nuclear Assurance {_such as source surveillance, and audits), and Desien Hasis Engineering huch as source inspection) are
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Docket bhunber 50-346 License Nurnber NPF-3 Sedal bhunber 2483
.Attaclunent 1
~ INFORMATION ONLY 17.2.7.4 Acceptance of Services Services such as inspection, engineering and consulting service ; and installation, repair, overhaul or maintenance work is accepted by performing a technical verification of data provided, surveillance or audit of the 10 activity, c a review of objective evidence for conformance to the procurement document requirements such as certifications, stress reports or inspection reports.
17.2.8 IDENTIFICATION AND CONTROL OF HATERIALS. PARTS AND COMPONENTS I
1 17.2.8.1 General 5
Procedures have been developed by Davis-Besse Supply, Engineering and 20 Plant Maintenance for the identification and control of materials, consum-5 ables, parts, spare parts, components, subassemblies, including subdivided materials. These procedures have been established to ensure that identifi-cation is maintained either on the item or on records traceable to the item to preclude use of incorrect or defective items or materials.
Procurement activities are controlled in accordance with Section 17.2.4.
Items such as chemicals, reagents, solvents, petroleum products, asbestos, and hazardous or radioactive materials are identified and controlled to preclude contamination or damage to the station and to prevent injury to personnel.
Items having limited storage life or operating life are identified and controlled to preclude inadvertent use of items with an expired shelf life l14 or operating life.
l5 Filler metal used during weld operations is purchased, received, stored and released under controlled conditions. While in storage, filler metal is stored in accordance with the manufacturer's recommendations, and each 5
h at and lot is kept segregated from other heats and lots in storage bins 9
or holding ovens. Only one type and heat /lct of electrodes or rod are issued at any given time.
The quantity of filler metal issued and the l8 quantity of .tused filler metal or stubs returned is documented.
l5 17.2.8.2 Identification Identification requirements are established during the generation of specifications, drawings or procurement documents. Physical identifica-tion is specified to the maximum extent possible. Where physical identi-fication on the item is either impractical or insufficient, tagging, or other appropriate means such as documentation traceable to the item 5
is utilized.
The identification of items is maintained by means such as part number, serial number or heat numbers throughout fabrication, installation, repair, modification, maintenance and use of the item. Traceability of items to i
l 17.2-29 REV 20 12/96 i
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Docket Number 50-346 License Number NPF-3 Serial Number 2483 Page 12 D-B 17.2.9.4 Nondestructive Examination l1 The quality Control Section has the responsibility for the development 8
and qualification of Davis-Besse Nuclear Power Station NDE procedures 14 in compliance with the applicable codes and standards. These procedures 1
are approved by a Level III in the appropriate NDE method. Engineering 14 also has the responsibility for specifying the appropriate NDE method 19 for each repair or modification and for assigning qualified personnel 14 to perform NDE.
1 Personnel performing nondestructive examinations are required to' be certified in accordance with the provisions of SNT-TC-1A.
1 When the services of an outside agency is required, these services are obtained through the procurement process. The contracted agency's Level III may be appointed in writing by the Director - Nuclear Assurance to act 18 as a Level III for the Davis-Besse Nuclear Power Station.
l14 17.2.10 INSPECTION 17.2.10.1 General Inspections are perfomed on activities affecting quality to verify conformance with related design drawings, specifications, and other controlling documents, and to ensure that maintenance, repair or modifica.
I tion work has been satisfactorily completed. Individuals performing inspections are other than those who performed or directly supervised the activity being inspected.
The Inservice Inspection Program is conducted in compliance with 10CFR50.55a.Section XI of the ASME Boiler and Pressure Vessel Code. USAR and Technical Specification requirements.
When the quality cannot be verified during inspection of the end product, 1
the Quality Control Section utilizes direct in-process inspections of work 8
activities. If inspection of the work is impossible or inconclusive, 1
indirect control by the monitoring of process methods, equipment, and personnel is provided. Both inspection and process monitoring are provid-ed when necessary to ensure adequate control.
17.2.10.2 Procedures l1 The Nuclear Quality Assurance Manual contains provisions which require 1
that maintenance, repair or modification procedures t
the Nuclear Assurance Department for review. Q; M i 1...u.i s... J 18 are required to prepare inspection procedures and chrckIIsts f rom in ormation 1
obtained from design documents and work controlling procedure s to determine which inspections are required and the acceptance and rejecti )n criteria.
Uhen Engineering establishes additional requirements or crite ria, these are 19 also included in the inspection checklists.
9 InSDettion personnel (Nuclear Safety & Inspection OC personnel, and Desien Basis Eneineerine receint/ source inspection personnen 17.2-32 FIV 19 5/9
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Docket Number 50-346-License Number NPF-3 Serial Number 2483
, Attachment 1
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on Page 13-l i
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I inspector (Nuclear Safety & Inspection OC nersonnel, or I
inn Basis Eneineerine recelot/ source inspection personnel.
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Appropriate hold and witness' points are specified in work controlling 5
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documents. When a hold point has been reached, work cannot proceed beyond 5
j oint mnt i
ectio is either performed or waived by an authorized" 5
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d::!,- r E : ^"- Mty er m
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17.2.10.3 Personnel Qualifications 5
Personnel perforining inspection functions are qualified through an estab-5
.11shed documented program in accordance with the requirements of ANSI 5
N45.2.6 as endorsed by NRC Regulatory Guide 1.58.
Training and qualification 9
l records are maintained in an up-to-date status by the Nuclear Assurance 18 1
Department.
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-17.2.10.4 Supplier Control 5
Suppliers are required to establish and implement an inspection program to ensure that procurement document requirements are satisfied. Nuclear 18 5
Assurance personnel p
_Jelective surveillance inspections to 5
evaluate and monitorgg::f:. i..Co verify adherence to procurement
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document requirement i. A system of mandatory hold points is established for j
critical operations ind inspections to permit witnessing of such operations and inspections.
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' Contractors that per form special purpose. inspections, such as inservice l
inspections, perform such work under the control of onsite supervision.
l This provides assura.tce that contractor personnel, equipment and proce-dures are properly q nalified and adequate to perform the inspection.
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l plan 1 processes, and Desien Basis Eneineerine personnel j
perform seicetive inspections j
l 17.2-33 REV 19 5/95 I
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Docket Number 50-346 License Number NPF-3 Serial Number 2483
. Attachment 1 Page f4
- INFORMATION ONLY
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17.2.10.5 Inspection Reports 1
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Each inspection activity is documented and the results are reviewed 9
to ensure that inspections were properly performed and documented. The 9
inspection reports are also reviewed to ensure inclusion of the following information.
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Identification of characteristics and activities inspected.
a.
b.
Inspection results, including objective evidence that acceptance
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criteria has been fulfilled.
Identification of reference documents such as procurement documents.
c.
1 drawings, specifications, work orders and procedures, d.
Idet.tification of inspector and date(s) of inspection.
e.
Identification of H&TE used, when applicable.
f.
Identification of person approving inspection results.
g.
Information pertaining to conditions adverse to quality discovered as a result of the inspection.
17.2.11 TEST CONTROL 17.2.11.1 General A testing program has been established which is planned and crecuted to 1
casure that testing is performed to demonstrate-that structures, systems 1
cnd components will perform satisfactorily in service. Testing is accom-1 plished in accordance with controlled written test procedures prepared by 1
Plant Operations and Engineering that incorporate the requirements and 19 l
acceptance limits established to verify operability or functional performance.
1 Test results are documented and evaluated to assure that requirements have 1
been satisfied.
I 17.2.11.2 Types of Tests 1
1 i
SURVEILLANCE and' PERIODIC TESTS are performed to determine continuing 1
functional readiness and adequacy for those systems and components which 1
.cre normally in a standby condition or to evaluate whether there has been 1
.cny degradation of performance, or any departure from the prescribed 1
cperating conditions for the systems and components which are normally in 1
.ssrvice. Surveillance tests are written to implement the surveillance 1
requirements contained Jn the Technical Specifications.
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g,3 documented to verify compliance with storage requirements to prevent 5
deterioration.
Cleaning operations are performed as necessary prior to preservation, packaging, storing or installing items to the level specified in proce-dures or procurement documents.
The. requirements for verifying and documenting ' the performance of cleaning operations and the resulting level of cleanliness is also specified.
The controls for releasing items from storage for installation or usage is defined in written procedures. These procedures specify measures for traceability from the Purchase Order to the area of installation or usage, authorized withdrawal and return of the items to storage. The procedures also' describe an inventory control system for " limited life' items (in.
ciuding consumables) which precludes issuance of' items whose shelf life has expired without reassessment of their suitability for use.
17.2.13.4 Shipping
' Procurement documents and shipping procedures specify special environment tal protection requirements during transit to ensure that damage of the shipped item is minimized. These documents include precautions for handling items during loading, unloading. 1 Transit marking and labeling 9
is also' required to be adequate to identify, maintain and preserve the' 5
shipment, including indication of the present of special environments, or the need for special controls.
17.2.14 INSPECTION, TEST, AND OPERATING STATUS 17.2.14.1 General Measures have been established in the Nuclear Quality Assurance Program that require contractors and onsite organizations to indicate the inspec-I tions, test, and operating status of structures, systems, and components by f
suitable methods of identification and in associated records. These measures are required to prevent the inadvertent'use of nonconforming, inoperative, or malfunctioning systems, structures or components, and to readily verify that required inspections and tests have been performed.
Written procedures describe the process for tagging and documenting the status of valves, breakers, and related controls for inspection, 3
test or j
maintenance. These procedures'also describe the methods for altering the i
sequence of required tests, inspections, and other operations important to safety to ensure that' equivalent reviews and approvals are performed.
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17.2.14.2 Inspection Status and Design Basis Engineering have j
h Nuclear Assuranceh_.%.-khchthYresponsibility for maintaining 18 j
procedures which address inspection status indicators that provide means 5
for assuring that required inspections are performed and that the accept-sbility of items with regard to inspections is known. The status indica-tion is accomplished by'such means as physical location. tags, markings, j
work travelers, stamps, inspection records. or other suitable means. The 17.2-40 REV 18 11/93
Docket Number 50-346 License Number NPF-3 Serial Number 2483
- Attachment 1 Page 16'
-m receipt inspection D-B authority for application and removal of status in icators lo specified in 5
procedure and documents that control the activity Haterials and items received at Davis-Besse are inspected for shipping 5
damage by Davis-Besse Supply. If no damage'is noted, the. material or item 20 tanned and placed into a Hold Area for pro escing through." d- '-~
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Damaged materials are also iden ified with a Hold fDr Acceptance 5
~ Tag, placed in a Hold Ares _and processed as a nonconformance. Items or 5
materials ac_cented byC;thi-O--1:N'gre identified individually or by 5
bulk { p. ij. L g q Q ad placeT in storage.
5 Logs, status boards or displays, and tags are used to identify inoperable or off-normal equipment. Release of equipment for maintenance,.aodifica-l tion, or test, maintaining the status indicators during work activities.
l and the return of equipment is controlled and documented by the Shift i
supervisor in accordance with administrative procedures.
Prior to authorizing the release of equipment for maintenance, modifica-tion, or test, the Shift Supervisor verifies that plant status will allow the release of equipment, and assures that plant operating perr0anel are cognizant of changes in equipment status,' including the degree of poten-tially. degraded protection when a redundant safety system or a safety system support system has been removed from service.
Equipment authorized to be removed from service is controlled to assure personnel and reactor safety. These controls include safety tags and other appropriate measures that administratively and, if required, physi-cally prevent unauthorized operators.
5 Associated valves, breakers, controls, etc., are placed in their proper configuration, and tagged at each location that the equipment can be operated. Independent verification by qualified operations personnel is performed to assure that the correct equipment has been removed from service and is placed in the proper configurat Mc..
Control Room tagouts are designated and affixed to prevent obstruction of other controls, instruments, or indicating lights.
Status boards and displays are used by licensed and non-licensed operators to provide visual display of the plant status and the inoperability of essential equipment. Status indicators are controlled and maintained
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current to reflect the operational status of plant structures, systems and components at all times.
When equipment is returned to service, safety tags are removed and status i-indicators inform personnel of the equipment's updated operational status.
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(e.e.. Accept Tse) i 1
17.2-41 REV 20 12/96
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l ATTACHMENT 2 DAVIS-BESSE NUCLEAR POWER STATION EVALUATION OF PROPOSED QUALITY ASSURANCE PROGRAM REDUCTIONS t
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4, Docket Numbcr 50-346 License Number NPF-3 Serial Number 2483 Attac,hment 2 i
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DAVIS-BESSE NUCLEAR POWER STATION (DBNPS)
USAR CHAPTER 17.2," QUALITY ASSURANCE DURING THE OPERATIONS PHASE" 10 CFR 50.54 EVALUATION FOR UCN 97-062 CHANGES IN QUALITY ASSURANCE PROGRAM MATERIAL RECEIFT INSPECTION PROCESS AND RESPONSIBILITIES 1
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SUMMARY
OF MODIFICATIONS l
l The changes to Updated Safety Analysis Report (USAR) Chapter 17.2, Quality Assurance During the Operations Phase (i.e., the Nuclear Quality Assurance Program Description (NQAPD)), proposed in USAR Change Notice (UCN)97-062 transfer most material receipt inspection functions from the DBNPS Nuclear Assurance Department's Nuclear Safety &
Inspection Section to the Engineering and Services Department's Design Basis Engineering Section, and change references to the specific inspection status " Accept Tag".
PROPOSED CHANGES The proposed changes to the US AR Chapter 17.2, which constitutes the DBNPS QA Program, are shown as the typed, bolded, underlined, and ballooned changes on the marked-up USAR pages of Attachment 1 and are reductions in committrents under 10 CFR 50.54(a).
DESCRIPTION OF MODIFICATIONS A description of each proposed modification to USAR Chapter 17.2 is described in this section of the 10 CFR 50.54 (a) evaluation. These reduction-in commitment modifications described in this evaluation are bolded as indicated below. These modifications correspond with the reduction changes as typed, bolded, underlined and ballooned on the marked-up USAR pages in Attachment 1.
1) 17.2.1.4, Page 17.2-5: Delete " receipt inspections, vendor surveillance and review of vendor supplied documentation," from the fourth sentence of the Manager - Nuclear Safety and Inspection position description and add a new sentence: "He is also responsible for receipt inspections, source inspections, and review of vendor l
supplied documentation associated with nuclear fuel and radioactive waste."
2) 17.2.1.4, Page 17.2-5: Add " plant" to the last sentence of Manager - Nuclear Safety &
Inspection position descriptic,n: "The Manager - Nuclear Safety and Inspection is I
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' Docket Number 50-346 License Number NPF-3 Serial Number 2483 Page 3 '
responsible for coordinating plant inspection and examination services provided by the l
Centerior Service Company."
i 3) 17.2.1.4, Page 17.2-8: Add " including receipt inspections, source inspections, and review of vendor supplied documentation (except for nuclear fuel and radioactive waste)" to the third sentence of the M:mager - Design Basis Engineering position description: "He is responsible for functions relating to: reliability and risk assessment; nuclear reactor analysis; nuclear safety analysis; simulator engineering; reactor engineering; nuclear fuel procurement, performance and design; reactor refueling; core physics testing; and procurement engineering including receipt inspections, source inspections, and review I
of vendor supplied documentation (except for nuclear fuel and radioactive waste)."
l 4) 17.2.1.4, Page 17.2-8: Add " receipt and source inspection," to the last sentence of the Manager - Design Basis Engineering position description: "He is also responsible for installation, improvements and maintenance of plant computer monitoring, computer aided engineering systems, and coordinating nuclear fuel procurement, receipt and source inspection, and computer related services provided by the Centerior Service Company."
5) 17.2.4.3, Page 17.2-23: Delete the second sentence of the first paragraph: "The Nuclear Assurance Department will also review selected procurement documents including those that require source inspection or unique receipt inspection activities."
6) 17.2.4.3, Page 17.2-23: Add "and hold / witness points; and that the supplier is included on a listing of approved vendors" to the first sentence of the second paragraph: " Review and approval by procurement engineers assures that the technical and quality requirements are sufficient, clear and adequately stated; can be inspected and controlled; and include adequate accept / reject criteria and hold / witness points; and that the supplici is included on a listing of approved vendors."
7) 17.2.4.3, Page 17.2-23: Add a new third sentence to the second paragraph: " Procurement documents include criteria prepared by procurement engineers that describe the characteristics to be inspected at receipt inspection."
8) 17.2.4.3, Page 17.2-23: Delete the third paragraph: "The multiple reviews conducted by Davis-Besse Supply, and where applicable the Nuclear Assurance Department, are performed to assure that quality requirements are sufficient, clear and adequately stated; inspectability requirements are satisfied; hold or witness points are adequate; accept / reject criteria are included; the checklist prepared by Davis-Besse Supply are included that describes the characteristics to be inspected at receiving inspection; and that the supplier is included on a listing of approved vendors."
Docket Number 50-346 License Number NPF-3 Serial Number 2483 Attac,hrnent 2 Page 4 9) 17.2.7.2, Page 17.2-28: Add " Design Basis Engineering" to the first sentence of the second paragraph: " Procedures have been developed by Design Basis Engineering and Nuclear Assurance that describe the criteria for determining the type of verification i
required during fabrication, inspection, testing and shipping at the vendor's facility, including methods for incorporating these provisions into procurement document j
requirements."
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- 10) 17.2.7.2, Page 17.2-28: Modify the second sentence of the second paragraph: " Source verification action by Nuclear Assurance (such ns source surveillance and audits) and Design Basis Engineering (such as source inspection) are performed to confirm that
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procurement document requirements have been satisfied."
- 11) 17.2.7.3, Page 17.2-28: Change " Receiving Inspection" to " receipt inspection" in the first l
sentence of the first paragraph: " Items purchased for use in quality related applications I
are processed through receipt inspection prior to storage, installation or use."
- 12) 17.2.7.3, Page 17.2-28: Add " Design Basis Engineering and" in the third paragraph:
"The methods used for verifying the validity of Certificates of Conformance, Certificates of Compliance or material physical or chemical analysis reports are identified by Design Basis Engineering and Nuclear Assurance Department procedures."
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- 13) 17.2.7.3, Page 17.2-28: Add " Design Basis Engineering or", change "with an" to "e.g.,"
to the fourth paragraph: "Upon completion of receiving inspection activities, accepted items are identified (e.g., Accept Tag) and released by Design Basis Engineering or Nuclear Assurance to Davis-Besse Supply for storage or issue."
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- 14) 17.2.10.2, Page 17.2-32: Change " Quality Control" to " Inspection (Nuclear Safety &
Inspection QC personnel, and Design Basis Engineering receipt / source inspection personnel)" in the second sentence of the paragraph: " Inspection personnel (Nuclear Safety & Inspection QC personnel, and Design Basis Engineering receipt / source 1
inspection personnel) are required to prepare inspection procedures and checklists from 1
- information obtained from dNgn documents and work controlling procedures to determine which inspections are required and the acceptance and rejection criteria."
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- 15) 17.2.10.2, Page 17.2-33: Change " designee from Quality Control" to " inspector (Nuclear Safety & Inspection QC personnel, or Design Basis Engineering receipt / source inspection personnel)" in the second sentence of the paragraph: "When a hold point has been reached, work cannot proceed beyond that point until inspection is either performed or waived by an authorized inspector (Nuclear Safety & Inspection QC personnel, or Design Basis Engineering receipt / source inspection personnel)."
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Docket Number 50-346 License Number NPF-3 Serial Number 2483 Page'5 *
- 16) 17.2.10.4, Page 17.2-33: Add " plant" and " Design Basis Engineering personnel perform selective inspections" to the second sentence of the first paragraph: " Nuclear Assurance personnel perform selective surveillance inspections to evaluate and monitor plant processes, and Design Basis Engineering personnel perform selective inspections to verify adherence to procurement document requirements."
- 17) 17.2.14.2, Page 17.2-40: Add "and Design Basis Engineering have" to the first sentence of the first paragraph: " Nuclear Assurance and Design Basis Engineering have the responsibility for maintaining procedures which address inspection status indicators that provide means for assuring that required inspections are performed and that the acceptability of items with regard to inspections is known."
- 18) 17.2.14.2, Page 17.2-41: Change " Receiving Inspection" to " receipt inspection" in the second sentence of the second paragraph: "If no damage is noted, the material or item is tagged and placed into a Hold Area for processing through receipt inspection."
- 19) 17.2.14.2, Page 17.2-41: Change " Receiving Inspection" to " receipt inspection" and "with an" to "e.g.," in the last sentence of the second paragraph: " Items or materials accepted by receipt inspection are identified individually or by bulk (e.g., Accept Tag) and placed in storage."
REASON FOR MODIFICATIONS The reason for each Quality Assurance Program modification is discussed below. The next section evaluates these modifications.
~ 1)
This change eliminates the Nuclear Safety & Inspection Section's responsibilities for receipt inspection, vendor surveillance inspection (aka source inspection) and review of vendor supplied documentation (except fuel and radioactive waste) and transfers these responsibilities to the Design Basis Engineering Section (see item #3 below).
2)
This change restricts Nuclear Safety & Inspection's coordination of inspection and examination services provided by Centerior Service Company to only " plant" inspections and examinations.
3)
This change adds receipt inspections, source inspections, and review of vendor supplied documentation to the Design Basis Engineering Section (except nuclear fuel and radioactive waste).
4)
This change adds coordination of receipt and source inspection services to the Design Basis Engineering Section.
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- 5) - This change removes the Nuclear Assurance review of procurement documents from the Procurement Document Review discussion. The Nuclear Assurance Department
_ performs this function under the independent audit process required by 10 CFR 50 Appendix B Criterion XVIII, Technical Specification 6.5.2.8 and USAR 17.2.18.1.
6)
This change transfers procurement document review for hold-witness points and supplier inclusion on a listing of approved vendors from Davis-Besse Supply to the Design Basis Engineering procurement engineers.
'7)L This change assigns the preparation of receipt inspection criteria, as documented in procurement documents, to the procurement engineers.
8)' This change removes responsibility for procurement document review for receipt / source from the Nuclear Assurance Department (see item 5 above). The remainder of the requirements in this. third paragraph are duplicated in the first two paragraphs of USAR Section 17.2.4.3. Elimination of this third paragraph will remove this duplication.
9)
This change adds source verification to Design Basis Engineering. Source inspection will be done by Design Basis Engineering while the Nuclear Assurance Department's activities will generally focus on vendor audits and smveillances.
- 10). This change adds source verification responsibilities to Design Basis Engineering.
Source inspection will be done by Design Basis Engineering while the Nuclear Assurance Department's activities will generally focus on vendor audits and surveillance.
I1) This change revises " Receiving Inspection" to " receipt inspection" to better describe the activity performed.
- 12) This change removes verification of Certificates of Conformance, Certificates of Compliance, and material physical / chemical analysis reports from the Nuclear Assurance Department (except for nuclear fuel and radioactive waste) and adds the function to Design Basis Engineering.
- 13) This change transfers receipt inspection and item inspection status tagging and item release from Nuclear Assurance (except for nuclear fuel and radioactive waste) to Design l.
Basis Engineering. The change also clarifies the requirement for a specific " Accept Tag".
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- 14) ~ This change allows Design Basis Engineering receipt / source inspection personnel to prepare inspection procedures and checklists.
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- 15) ~ This change requires designated Design Basis Engineering receipt / source inspection personnel to perform / waive hold points inspections.
-16) This change limits Nuclear Assurance Safety & Inspection functions to plant processes and transfers some receipt / source inspection activities to Design Basis Engineering.
- 17) This change allows 1;esign Basis Engineering, as well as Nuclear Assurance, to prepare / maintain inspection status procedures to support their receipt / source inspection activities.
- 18) ' This change revises " Receiving Inspection" to " receipt inspection" to better describe the activity performed.
- 19) This change revises " Receiving Inspection" to " receipt inspection" to better describe the activity being performed and clarifies the requirement for a specific " Accept Tag".
EVALUATION The receipt / source inspection function was originally part of the station operations group
~(circa early 1970's) but has been part of the Nuclear Assurance (aka Quality Assurance /
' Quality Control) organization for over twenty years. The function was transferred to the Quality Control section in 1976.(prior to the DBNPS's commercial operation) as site quality assurance audit / inspection activities were consolidated under the growing Quality Assurance department.
The proposed changes primarily involve the transfer of the receipt and source inspection-related functions (except inspection of radioactive waste and nuclear fuel) and receipt inspection personnel from Nuclear Assurance to Design Basis Engineering procurement engineering. Following approval and implementation of this change, the receipt / source inspection activities will be divided between " plant" inspections (including radioactive waste and nuclear fuel which are inspected in the plant), and " warehouse / vendor" inspections (services and components).
1 The following activities are presently performed by Nuclear Assurance receipt inspection
. personnel and, under this change, will be performed by Design Basis Engineering personnel as part of the procurement engineering function assuring that vendors meet purchase requirements:
preparing receipt / source inspection procedures and checklists, e
h review of procurement documents for receipt / source inspection planning (including inspection criteria, hold / witness points, and supplier inclusion on the Approved Vendors List),
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' receipt / source inspection review / verification of vendor supplied documentation (including e
Certificates'of Conformance, CeWicates of Compliance, and material physical / chemical analysis reports),
receipt / source inspection (ii,iuding performing / waiving hold points),
e receipt / source inspection acceptance status tagging, e
item receipt / source inspection release, and e
. coordination of corporate receipt / source inspection services.
The Nuclear Assurance Department's Nuclear Safety & Inspection Section will maintain responsibility for training and qualification of receipt / source inspection personnel, including Design Basis Engineering's inspectors, under NRC Regulatory Guide 1.58 and ANSI
' N45.2.6-1978 requirements (including maintaining associated records). The Nuclear Safety &
Inspection Section QC inspectors will also continue to conduct inspections supporting radioactive waste shipments and nuclear fuel activities. Additionally, the Nuclear Assurance
' Department's Nuclear Safety & Inspection Section will continue to be responsible for plant inspection / examination related activities to support plant operation, maintenance and modification activities and will still coordinate corporate services involving plant inspections / examinations.
Transferring the receipt inspection function will eliminate an element of independent _ quality assurance oversight of procurement activities. However, the Technical Specification 6.2.1.d requirements for the Quality Assurance function's organizational freedom and independence from operating pressures v,ould continue to be satisfied as follows:
Nuclear Assurance / Quality Assessment auditors will continue to prc. vide independent u
quality assurance oversight / checking of procurement engineering functions, including receipt / source inspection, during surveillance of related processes and audits' performed
. pursuant to 10 CFR 50 Appendix B Criterion XVIII, Technical Specification 6.5.2.8 and USAR 17.2.18.1 requirements.
The receipt inspection responsibilities being transferred will continue to be performed by
' ANSI N45.2.6 qualified personnel independent from the organizations being inspected. The inspection functions will be performed by the same personnel. The qualification function will continue to be administered by.the Nuclear Assurance Department's Nuclear Safety &
. Inspection Section to maintain independence in inspector training and qualification. USAR 17.2.10.1 inspection requirements that " individuals performing inspections are other than those who performed or directly supervised the activity being inspected" will continue to be satisfied as individuals performing receipt / source inspections will be other than those who
= performed or directly supervised the vendor products and documentation being inspected.
Docket Number 50-346.
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- In addition, Design Basis Engineering receipt / source inspectors will not be subjected to the -
same operational pressures as those engineers involved with daily plant operation (e.g., system engineers) since they will be part of the design control function ensuring that purchased -
material and equipment conform to design / procurement specifications. Also, procurement engineers will continue to perform self-sponsored peer reviews for checking procurement engineering products and services.
' Modifications #13 and #19 change the applicable USAR references to the inspection " Accept Tag" as the only means for physical identification of inspection status. These modifications will allow status indication to be accomplished by other suitable physical indicators such as location, tags, markings /bar coding, work travelers, stamps, or inspection records, or other means provided under the requirements of USAR 17.2.14.2," Inspection Status".
The proposed changes discussed above (modifications 1 through 19) are reductions to existing commitments under 10 CFR 50.54(a) in regards to procurement-related oversight performed -
during receipt inspection by the Nuclear Assurance Department. However, none of the proposed changes will reduce the effectiveness of any program or add any non-quality assurance functions to a Quality Assurance group.
In conclusion, all requirements of 10 CFR 50 Appendix B, the DBNPS NQAPD-committed.
NRC Regulatory Guides and ANSI Standards, the Operating License and Technical Specifications, and associated systematic activities and functional responsibilities, will continue to be satisfied by the DBNPS Nuclear Quality Assurance Program as described in USAR Chapter 17.2 following NRC approval of the above proposed changes.
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REFERENCES l
l 10CFR50.54(a)(Changes to the Quality Assurance Program) e 10CFR50 Appendix B Criterion I(Organization)
L 10CFR50 Appendix B, Criterion IV (Procurement Document Control) 10CFR50 Appendix B, Criterion VII (Control of Purchased Material, Equipment, and
' Services) 10CFR50 Appendix B, Criterion X (Inspection) e 10CFR50 Appendix B, Criterion XIV (Inspection, Test, and Operating Status) e ANSI /ANS-3.2-1982 (Administrative Controls and Quality Assurance for Operational Phase)
ANSI N45.2.2-1972 (Packaging, Shipping, Receiving, Storage and Handling of Items) e USAR Chapter 17.2 (Quality Assurance During the Operations Phase)
ANSI N45.2.6-1978 (Qualifications of Inspection, Examination and Testing Personnel)
Technical Specifications Section 6.0 (Administrative Controls) e
. Regulatory Guide 1.58, Rev 1,1980 (Qualification of Inspection, Examination and Testing Personnel) 4 l
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