Text

Rev 55 to CE-1-A, QA Program for Nuclear Generating Stations
	ML20245F870
Person / Time
Site:	Dresden, Byron, Braidwood, Quad Cities, Zion, LaSalle, 05000000
Issue date:	03/27/1989
From:	; COMMONWEALTH EDISON CO.
To:	;
Shared Package
ML20245F875	List: ML20245F870; ML20246B950;
References
	CE-1-A, NUDOCS 8905030025
	Download: ML20245F870 (129)
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my ,,j. l[:;E P CE-1-A Topical Report Revision.55. 4 fj - I, .g ~ d . QUALITY ASSURANCE PROGRAM' FOR NUCLEAR GENERATING STATIONS ] f 1 l 1 Connonwealth Edison Company y. 89050300259904gg PDR ADOCK OSOOT)DH gO

n 1 h4 CE-1-A Topical Report Jardary 1976 Rev. 55 - 3/27/89 l C 0 M M 0 N W E A L'T H EDIS0N C0MPANY QUALITY ASSURANCE PROGRAM FOR NUCLEAR GENERATING STATIONS I COMMONWEALTH EDISON COMPANY Post Office Box 767 Chicago, Illinois 60690 i ....,A

w LISTING COVERING REVISION OF TOPICAL REPORT CE-1-A Below is a listing of Revision 55 changes to the Commonwealth Edison Company Quality Assurance Program Topical Report CE-1-A dated 3/27/89: Rev. Content Pages 1-4; Pages 1 1-53; 2 2-8; 3 3-4; 4 4-4; 5 5-2; 6 6-3; 7 7-6; 8 8-2; 9 9-3; 10 10-2; 11 11-4; 12 12-3; 13 13-3; 14-1; 15 15-3; 16 16-2; 17-2; and 18 18-3. Approved: ynagerofQualityAssurance/ Nuclear Safety I 3/27/89 9518M b________.________________.

I w on CONTENTS TITLE g ggy. JgL INTRODUCTION 1-1 55 03/27/89

1. ORGANIZATION A.

Basic Organization Responsibilities 1-1 55 03/27/80 1-2 55 03/27/89 B. Organizational Responsibilities for Major Activities 1-3 55 03/27/89 1-4 55 03/27/89 1-5 55 03/27/89 1-6 55 03/27/89 1-7 55 03/27/89 1-8 55 03/27/89 1-9 55 03/27/89 1-10 55 03/27/89 1-11 55 03/27/89 1-12 55 03/27/89 1-13 55 03/27/89 1-14 55 03/27/89 1-15 55 03/27/89 1-16 55 03/27/89 1-17 55 03/27/89 1-18 55 03/27/89 1-19 55 03/27/89 1-20 55 03/27/89 1-21 55 03/27/89 1-22 55 03/27/89 1-23 55 03/27/89 1-24 55 03/27/89 1-25 55 03/27/89 1-26 55 03/27/89 1-27 55 03/27/89 1-28 55 03/27/89 1-29 55 03/27/89 1-30 55 03/27/89 1-31 55 03/27/89 1-32 55 03/27/89 1-33 55 03/27/89 1-34 55 03/27/89 1-35 55 03/27/89 1-36 55 03/27/89 1-37 55 03/27/89 1-38 55 03/27/89 1-39 55 03/27/89 1-40 55 03/27/89 1-41 55 03/27/89 1-42 55 03/27/89 1-43 55 03/27/89 Page _1_ of 4 Date: 3-27-89 Rev. 55 1

0*.

CONTENTS TITLE E&GE EgY. DATE FIGURES l 1-0~ Organization Chart Related To 0. A. 1-44 55 03/27/89 l 1-1 Organization Chart - Quality Assurance / 1-45 55 03/27/89 l Nuclear Safety Policy and Oversight Dqpt. 1-1-1 Quelity Programs and Assessment Department 1-46 55 03/27/89 1-2 Engineering and Construction-Department 1-47 55 03/27/89 1 2.1 Ceco Nuclear Generating Station Site 1-48 03/27/89 Organization Interface Relationships 1-3 Projects Organization and Nuclear 1-49 55 03/27/89 Engineering Department. 1-4 Projects Department (For Future Project - 1-50 55 03/27/89 Currently Inactive) 1-5 System Operational AnalysiJ Department 1-51 55 03/27/89 and System Materials Analysis Department 1-6 Production 1-52 55 03/27/89 1-7 Station Production ~ Department Organization 1-53 55 03/27/89

2. QUALITY ASSURANCE PROGRAM 2-1 51 07/07/88 2-2 51 07/07/88 2-3 55 03/27/89 2-4 55 03/27/80 2-5 55 03/27/89 2-6 55 03/27/89 2-7 55 03/27/89 2-8 55 0,3/27/89

3. DESIGN CONTROL 3-1 55 03/27/89 3-2 55 03/27/89 3-3 55 03/27/89 3-4 55 03/27/89

4. PROCUREMENT DOCUMENT CONTROL 4-1 55 03/27/89 4-2 55 03/27/89 4-3 55 03/27/89 4-4 55 03/27/89 4-5 16 03/16/81

5. INSTRUCTIONS, PROCEDURES AND DRAWINGS 5-1 55 03/27/89 5-2 55 03/27/89 5-3 36 06/19/85

6. DOCUMENT CONTROL 6-1 32 10/05/84 6-2 55 03/27/89 6-3 55 03/27/89 Page _2_ of 4 Date:

3/27/89 Rev. 15

CONTENIS TITLE EAGI EIY. DATE

7. CONTROL OF PURCHASED MATERIAL, EQUIPMENT AND SERVICES 7-1 55 03/27/89 7-2 55 03/27/89 7-3 55 03/27/89 7-4 55 03/27/89 7-5 55 03/27/89 7-6 55 03/27/89 8.

IDENTIFICATION AND CONTROL OF MATERIALS, PARTS AND COMPONENTS 8-1 55 03/27/89 8-2 55 03/27/89

9. CONTROL OF SPECIAL PROCESSES 9-1 55 03/27/89 9-2 55 03/27/89 9-3 55 03/27/89

10. INSPECTION 10-1 55 03/27/89 10-2 55 03/27/89 10-3 33 03/13/85

11. TEST CONTROL 11-1 15 01/02/81 11-2 55 03/27/89 11-3 55 03/27/89 11-4 55 03/27/89

12. CONTROL OF MEASURING AND TEST EQUIPMENT 12-1 42 11/21/86 12-2 55 03/27/89 12-3 55 03/27/89

13. HANDLING, STORAGE AND SHIPPING 13-1 26 12/10/83 13-2 55 03/27/89 13-3 55 03/27/89

14. INSPECTION, TEST AND OPERATING STATUS 14-1 55 03/27/89 14-2 26 06/19/85

15. NONCONFORMING MATERIALS, PARTS OR COMPONENTS OPERATIONS 15-1 26 12/10/83 15-2 55 03/27/89 15-3 55 03/27/89

16. CORRECTIVE ACTION 16-1 55 03/27/89 l

16-2 55 03/27/89 16-3 15 01/02/81

17. QUALITY ASSURANCE RECORDS 17-1 51 07/07/88 17-2 55 03/27/89 i

1 l Page _1_ of 4 Date: 3/27/89 Rev. 55

i e CONTENTS I l TITLE EhGE ggy. DATE

18. AUDITS 18-1 55 03/27/89 18-2 55 03/27/89 l'

18-3 55 03/27/89 APPENDIX A Quality Assurance Program Manual Index A-1 45 06/30/87 Quality Assurance Procedures Manual A-2 50 04/08/88 Index (Engineering and Construction) Quality Assurance Procedures Manual A-3 45 06/30/87 Index (Operations) A-4 50 04/08/88 A-5 45 06/30/87 Page _1. of _.L. Date: 3/27/89 Rev. 15 ,? Approved 5" / z [ anager of Quality Assurance / ( Nuclear Safety 9522M i l I _________._______..._________.____________________________i

( j.: r EXPLANATION OF CHANGES FOR TOPICAL REPORT - REV. 55 CCBG40NWEA TH EDISON COMPANY PROGRAM TOPICAL REPORT CE-1-A l-PAGE NO. EXPLANATION Pages 1 1-53; Commonwealth Edison has,recently 2 2-8; 3 3-4; conducted a self analysis of Company 4 4-41 5 5-2; organization in an cffort to improve 6 6-3; 7 7-6; effectiveness. The Topical Report 8-1 -~8-2; 9 9-3; revision is being made to reflect the 10 10-2; 11 11-4; organizational changes resulting from f 12 12-3; 13 13-3; the analysis. 14-1; 15 15-3; 16 16-2; 17-2; and 18 18-3. 0012M l

i 4 I L \\ APPENDIX A i QUALITY ASSURANCE PROGRAM, MANUAL INDEX 0 Preface 0 Introduction O ASME Code Interface 0 Definitions Quality Requirements 1.0' Organization 2.0 Quality Assurance Program 3.0 Design Control 4.0 Procurement Document Control 5 '. 0 Instructions, Procedures and Drawings 6.0 Document Control 7.0 Control of Purchased Material, Equipment and Services 8.0 Identification and Control of Materials, Parts and Components 9.0 Control of Special Processes 10.0 Inspection 11.0 Test Control 12.0 Control of Measuring and Test Equipment 13.0 Handling, Storage and Shipping 14.0 Inspection, Test and Operation Status A-1 i Rev. 45 6/30/87

Quality ~ Requirements 15.0 Nonconforming Materials, Parts or Components 16.0 ' Corrective Action L '17.0 Quality Assurance Records '18.0 Audits O Appendix B, 10CFR50, " Quality Assurance Criteria'for Nuclear Power Plants" O Station Quality Assurance Manual for Construction, Maintenance, Modification, In Service Inspection and Stores Activities QUALITY ASSURANCE PROCEDURES MANUAL INDEX (ENGINEERING & CONSTRUCTION) -Quality Procedures 2-1 Procedure for Revision of the Quality Assurance Manual '2-2 Training of Personnel to Meet Quality Assurance Requirements 3-1 Design Control and Maintenance and Modifications Control

2 3-2 Design Change Control 3-3 Classification of Systems, Components, Parts and Materials 4-1 Request for Bid, Proposal Evaluation and Recommendation 4-2 Evaluation of Contractor's Quality Assurance Program 5-1 Quality Instructions and Procedures 6-1 Distribution of Design Documents 6-2 Procedure !or Station Construction Department Design Document Control 7-1 Control-of Procured Material and Equipment - Receiving and Inspection 7-2 Off-Site Contractor Inspection A-2 Rev. 50 4/08/88

Quality Procedures ~< 8-1 Identification and Control of' Materials, Parts.and Components 9-1 Control of. Contractor Special Processes 10-1 On-Site Contractor Inspection 10-2' Quality Assurance Mandatory Hold / 11-1 Development, Performance, Documentation and Evaluation Of Construction Tests 11-2 Development, Performance, Documentation and Evaluation of Preoperational and Start-up Tests 12-1 Calibration Control of Commonwealth Edison Test and Measurement Equipment 12-2 Calibration and Control of Station Instrumentation and-Control Equipment 12-3 Review of Vendor / Contractor Calibration Activities and Quality Control Records 13-1 Site Handling, Storage, Preservation, Maintenance and Shipping of Material, Equipment and Components 14-1 Inspection and Test 15-1 Reporting Quality Nonconformances During Construction and Test 15-2 Reporting Significant Deficiencies that Occur During Construction and Test 16-1 Corrective Action for Reportable Deficiencies & Quality Nonconformances that Occur During Construction and Test 17-1 Quality Assurance Records 18-1 Quality Program Audits 18-2 Surveillance of Contractor Quality Assurance / Control Activities 18-2 ATTACHMENT A Quality Assurance Department Surveillance of Construction Activities QUALITY ASSURANCE PROCEDURES MANUAL INDEX (OPERATIONS) Quality Procedure 2-52 Quality Assurance Program for Operations - Training 2-53 Quality Assurance Program for Operations - Classification of Strt:tures, Systems and Components A-3 Rev. 45 6/30/87 L---_________-_-________

Quality Procedures 3-51 Design Control for Operations - Plant Modifications 3-52 Design Control of Operations - Plant Maintenance J 3-53 Design Control for Operations - Reactor Analysis l 3-54 Design Control for Operations - Digital Computer and Software { 4-51 Procurement Document Control for', Operations - Processing Purchase Documents 5-51 Instructions, Procedures and Drawings for Operations Procedures Manual 6-51 Document Control for Operations - Transfer of Records 6-52 Document Control for Operations - Distribution and Control of Engineering Docuraents and Drawing Change Control 7-51 Control of Purchased Materials, Equipment and Services for Operation - Supplier Evaluation 7-52 Control of Purchased Materials, Equipment and Services for Operation - Source Inspection 7-53 Surveillance and Audit of Nuclear Fuel Contractor 7-54 Inspection for Operations - Receiving Inspection

2 8-51 Identification and Control of Materials, Parts and Components for Operations - Identification, Inventory Disbursal and Use 9-51 Control of Special Processes for Operations - Special Processes for Maintenance and Modifications 10-51 Inspection for Operations - Maintenance 10-52 Inspection for Operations - Station Operations 10-53 Inspection for Operations - Technical Support, Surveillance and Inspection
w 11-51 Test Control for Operations - Planned Tests r

12-51 Control of. Measuring and Test Equipment for Operations Portable Test and Measurement Equipment 12-52 Control of Measuring and Test Equipment for Operations Station Instrumentation 12-53 Standardization and Control of Standard Colutions-Nuclear l Generating Stations 12-54 Calibration Control of Commonwealth Edison Analytical Chemistry & Radiochemistry Laboratory Instruments and Standards Nuclear Stations A-4 Rev. 50 4/08/88

Quality Procedures 13-51 Handling, Storage and Shipping for Operations - Control of Equipment, Materials and Nuclear Fuel 13-52 Preparation and Shipment of Radioactive Materials 14-51 Inspection, Test and Operating Sta,tus for Operations 15-51 Nonconforming Materials, Parts and Components for Operations - Spare Parts and Materials 15-52 Nonconforming Materials, Parts or Components for Operations - Deviations and Incidents 15-53 Nonconforming Materials, Parts and Components for Operations - Inspection and Test 16-51 Corrective Action for Operations - Corrective Action System 17-51 Quality Assurance Records for Operations - Control of Station Records 18-51 Audits for Operations - Quality Assurance Program Audits 18-52 Audit and Surveillance of Maintenance, Spare Parts and In-Service Inspection Activities A-5 Rev. 45 9520M 6/30/87

QUALITY ASSURANCE DURING DESIGN, CONSTRUCTION AND OPERATION Introduction This Topical Report has been prepared to delineate the requirements governing the Commonwealth Edison Company Quality Assurance Program for its nuclear generating stations. Implementation of the Program with Quality Procedures provides the degree of quality assurance commensurate with the requirements of ASME Section III, Division I and Division 2 for concrete containment and other applicable codes, Nuclear. Regulatory Commission requirements and Federal Regulations governing design, procurement. construction,-testing, operation, refueling, maintenance, repair and modification of Commonwealth Edi, son Company's nuclear power generating facilities. The scope of this Report covers the total i Quality Assurance Program for the life of the Commonwealth Edison Company generating plants commencing with the construction of the LaSalle County Station and for the operation periods of the previously built Dresden, Quad Cities and Zion plants and is

55 described 1r, the ensuing 18 sections of this Report.

1. Organization A. Basic Organization Responsibilities Commonwealth Edison Company is ultimately responsible for the assurance of quality in all phases of the design, procurement, construction, modification, testing and operation of the Station. Edison executes this responsibility in accordance with the program set forth in the Company Quality Assurance Manual and described herein and assigns areas of ultimate responsibility to specific Edison organizations and individuals. Inherent in the delegation of responsibilities is th? assignment of corresponding authority required to execute the responsibilities. Edison has delegated the responsibility for certain phe,ses cf the work to the Architect l Engineer and theJSSS Supplier, both of whom act as Edison's agents in the assigned areas. Edison maintains overall control of the efforts of these organizatices tiy various mechanisms such as design evaluation and audits. Edison has prime responsibility for contro111 reg the quality of on-site work by field contractors. Also, Edison retains overall responsibility for procurement, design, construction, modif'estions, and operation of the p! ant including certification and stamping in accordance with the ASME Code. I 1-1 Rev. 55 3/27/89 i Commonwealth Edison

Requirements (Operations)" as an acceptable methed of complying with the Commission's regulations with regard to overall quality assurance program requirements. The Program shall apply to the quality assurance activities affecting the safety-related j structures, systems and components. The Program is applicable to the maintenance, modification, operating and refueling quality assurance activities from the time the Operating License is issued to the end of the operating life of the items. Repairs are performed as maintenance activities and alterations as modifications. The Program covering operations., including quality control, is planned and implemented in accordance with procedures

ss necessary to provide Commonwealth Edison Company adequate confidence that a safety-related structure, system or component performs satisfactorily in service.

1 B. Organizational Responsibilities for Maior Activities Design Control of design quality is essentially a four-stage process. Designs originated by either the NSSS Supplier or Architect Engineer are subjected to internal review by the designer and an independent internal party (or parties). The NSSS Supplier and Architect Engineer designs are evaluated by each other as well as by personnel from one or more Edison departments. These steps constitute the primary design evaluation for all safety-related and ASME Section III items in the Station. Appropriate document distribution and control has been established to permit an effective effort in this area. Comments on designs resulting from these evaluations are presented in letter form, by telephone (with written follow-up) or in meetings with published minutes. Edison has final authority with respect to decision making on designs. Ernturement Procurement control and follow-up for NSSS components is established and maintained by the NSSS Supplier. Edison and the Architect Engineer evaluate the NSSS Supplier procurement specifications, and Edison audits and inspects the NSSS Supplier control measures. Procurement of and follow-up on non-NSSS components and services are directly controlled by Edison, based on the Architect Engineer specifi 4ns which have been evaluated by Edison. The Atrhitect Engineer is used to assist in this effort, as Edison's agent, as requested by Edison. Construction Construction quality assurance is an Edison responsibility. Edison exercises managerial control of all site construction activities. The site Quality Assurance Group maintains close surveillance of on-site contractor's and other associated construction quality assurance activities. The NSSS Supplier furnishes technical and Quality Control assistance for on-site activities relating to the NSSS. On-site contractors' quality assurance programs are independently evaluated by the Engineering

ss and Construction Department and Edison Quality Assurance.

1-3 Rev. 55 3/27/89 Commonwealth Edison

QUALITY ASSURANCE DURING DESIGN, CONSTRUCTION AND OPERATION Introduction This Topical Reprt has been prepared to delineate the requirements governing the Commonwealth Edison Company Quality Assurance Program for its naclear generating stations. Implementation of the Program with Quality Procedures provides the j degree of quality assurance commensurate with the requirements of ASME Section III, Division 1 and Division 2 for concrete containment and other applicable codes, Nuclear Regulatory Commission requirements and Federal Regulations governing design, procurement, construction, testing, operation, refueling, maintenance, repair and modification of Commonwetith Edi, son Company's nuclear power generating facilities. The scope of this Report covers the total Quality Assurance Program for the life of the Commonwealth Edison Company generating plants commencing with the construction of the LaSalle County Station and for the operation periods of the previously built Dresden, Quad Cities and Zion plants and is

ss described in the ensuing 18 sections of this Report.

1. Organization A. Basic Organization Responsibilities Commonwealth Edison Company is ultimately responsible for the assurance of quality in all phases of the design, procurement, construction, modification, testing and operation of the Station. Edison executes this responsibility in accordance with the program set forth in the Company Quality Assurance Manual and described herein and assigns areas of ultimate responsibility to specific Edison organizations and individuals. Inherent in the delegation of responsibilities is the assignment of corresponding authority required to execute the responsibilities. Edison has delegated the responsibility for certain phases of the work to the Architect Engineer and the._*iSSS Supplier, both of whom u t as Edison's agents in the astigned areas. Edison maintains overall control of the efforts of these organizations by various mechanisms such as design evaluation and audits. Edison has prime responsibility for ccatrolling the quality of on-site work by fleid contractors.

Also, Edison retains overall responsibility for procurement, design, construction, modifications, and operation of the plant including certification and stamping in accordance with the ASHE Code.

1-1 Rev. 55 3/27/89 Commonwealth Edison

The Commonwealth Edison Company Quality Assurance Program for nuclear generating stations covers the organization arrangement whereby the corporate policy and the performance of off-site audits for the area of Quality Asrurance involving nuclear and the corporate policy 6r Nuclear Safety are the responsibility of the Manager of Quality Assurance / Nuclear Safety, who reports to the Chairman and CEO. Also, the Assistant Vice President (Quality Programs and Assessment), and, in turn, the Nuclear Quality Programs Manager, direct the quality assurance activities for the design, procurement, construction, and operation of the Company's nuclear power facilities and interface activities with the Nuclear Regulatory Commission,

55 Office of Inspection and Enforcement, Region III, and the Jurisdictional Authority.

The Assistant Vice President (Quality Program and Assessment) reports to the Senior Vice President (Nuclear Operations), and functions independently of PHR (Pressurized Water Reactor) and BWR (Boiling Hater Reactor) operations. The Construction Manager, supported by Site Construction Superintendents, is responsible for administration of the contracts and for verification that construction activities carried out by site contractors conform to procurement document requirements which include performance and quality related functions. Also, the construction site group has responsibility for reviewing site contractor quality control procedures, preparing checklists for witnessing inspection notification points at vendor plants, inspection and designation of status of incoming material at the site, reviewing inspection procedures and monitoring quality control activities of contractors at the site. The Quality Assurance site group is responsible for assuring that the quality requirements are fulfilled and for final approval of: (1) quality assurance procedures of site contractors; (2) the program, including checklists and reports, for inspections and audits at contractor plants; (3) site receipt inspection of materials performed by others; and (4) for audit of contractor inspection activities at the site. Independent Inspection Agency inspection and testing activities performed directly for Commonwealth Edison are under the direction and responsibility of the Site Quality Assurance Superintendent and such Agency shall be staffed with qualified personnel acceptable to Quality Assurance. Such Agency has responsibility to identify unacceptable or nonconforming work occurring on-site and, when assigned, at off-site supplier's plants. An Independent Inspection Agency is assigned responsibilities for inspection and testing, to determine an:f report whether the item conforms to design, test and specification requirements and to reject unsatisfactory materials, equipment and other items. Such rejection by an Independent Inspection Agency will be the basis for action by the Commonwealth Edison site organizations to carry out necessary steps to assure rephir, rework or processing of a nonconformance report in accordance with the Quality Assurance Program. The Commonwealth Edison Company Quality Assurance Program includes the quality assurance requirements for operating nuclear power statiens. The Program covering operations shall comply with the 18 Criteria of the " Quality Assurance Criteria for Nuclear Power l Plants" of Appendix B to 10CFR50 for maintenance, modification and l refueling activities and with Criteria 1, 2, 5, 5, 10, 11, 12, 14, 15, 16, 17 and 18 for operating activities. As supplementary Criteria to J the 18 Criteria described above for Appendix B to 10CFR50, the Program j also compiles with Regulatory Guide 1.33 " Quality Assurance Program j 1-2 Rev. 55 1 3/27/89 i Commonwealth Edison i t________________

1 1 Requirements (Operations)" as an acceptable method of complying tsith the Commission's regulations with regard to overall quality assurance program requirements. The Program shall apply to the quality assurance activities affecting the safety-related structures, systems and components. The Program is applicable to the maintenance, modification, operating and refueling quality assurance activities from the time the Operating License is issued to the end of the operating life of the items. Repairs are performed as maintenance activities and alterations as modifications. The Program covering operations., including ouality control, is planned and implemented in accordance with procedures

55 necessary to provide Commonwealth Edison Company adequate confidence that a safety-related structure, system or component performs satisfactorily in service.

B. Organizational Responsibilities for Maior Activitin Desian Control of design quality is essentially a four-stage process. Designs originated by either the NSSS Supplier or Architect Engineer are subjected to internal review by the designer and an independent internal party (or parties). The NSSS Supplier and Architect Engineer designs are evaluated by each other as well as by personnel from one or more Edison departments. These steps constitute the primary design evaluation for all safety-related and ASME Section III items in the Station. Appropriate document distribution and control has been established to permit an effective effort in this area. Comments on designs resulting from these evaluations are presented in letter form, by telephone (with written follow-up) or in meetings with published minutes. Edison has final authority with respect to decision making on designs. Procurement Procurement control and follow-up for NSSS components is established and maintained by the NSSS SuppIler. Edison and the Architect Engineer evaluate the NSSS Supplier procurement specifications, and Edison audits and inspects the NSSS Supplier control measures. Procurement of and follow-up on non-NSSS components and services are directly controlled by Edison, based on the Architect Engineer spe:1fications which have.been evaluated by Edison. The Attbitect Engineer is used to assist in this effort, as Edison's Agent, as requested by Edison. Construction Construction quality assurance 15 an Edison responsibility. Edison exercises managerial control of all site construction activities. The site Quality Assurance Group maintains close surveillance of cn-site contractor's and other associated construction quality assurance activities. lhe NSSS Supplier furnishes technical and Quality Control assistance for on-site activities relating to the NSSS. On-site contractors' quality assurance programs are independently evaluated by the Engineering

55 and Construction Department and Edison Quality Assurance.

1-3 Rev. 55 3/27/89 Commonwealth Edison l

Pre-service Testing Pre-service testing, consisting of preoperational and start-up testing, is controlled by Edison. The Architect Engi'neer and the NSSS Supplier furnish rough draft test procedures to Edison. Based l 'on these, a final draft is written by Edison. This final draft is l subjected to internal Edison evaluation and evaluation by the Archi-tect Engineer or the NSSS Supplier as appropriate. The tests are managed and performed by Edison with technical assistance from the NSSS Supplier as appropriate. The evaluation of the test results is performed by Edison and confirmed by independent, internal Edison evaluations. Further independent evaluations by the Architect Engineer or the NSSS Supplier are performed as required by Edison. Ooerations Commonwealth's managerial and administrative control of the Quality Assurance Program for operating nuclear stations, as.illus-trated in Figures 1-0, 1-1, and 1-6 includes review and approval of procedures by the personnel described in this document. Quality Procedures and revisions thereto for the Company Manual are concurred with by the principally involved departments. The Nuclear Quality Programs Manager, reporting to the Assistant

55 Vice President (Quality Programs and Assessment), verifies that the Quality Procedures used by, or under the direction of, the station staff for operating, maintenance, modifications, in-service inspection and Stores activities contained in the Company Manual or Station Quality Procedures comply with the policy described in this document.

The Manager of Quality Assurance / Nuclear Safety approves the Quality Procedures covering operating, maintenance,

55 modifications, in-service inspection and Stores activities for use in the Station.

Station Procedures and instructions and revisions thereto for'the Station Procedures Manual are reviewed and approved as provided in the Technical Specifications. The Station Quality Assurance Engineers or Inspectors covering station operating

55 activities and reporting to the Station Quality Assurance Superintendent provide surveillance of the preparation and revision
55 of the station procedures and instructions for operating to assure compliance with the policies contained in the Quality Assurance Program.

The Quality Assurance Engineers or Inspectors for maintenance, also reporting to the Station Quality Assurance

55 Superintendent, provide surveillance of the preparation and revision of procedures and instructions for maintenance, modifications, in-service inspections and Stores activities to assure compliance l

with the policy contained in the Quality Assurance Program. Temporary changes to station operating procedures which do not

55 l

1-4 Rev. 55 3/27/89 Commonwealth Edison

change the intent of the original procedures may be made with the concurrence of qualified individuals as described by Technical Specifications. Such temporary changes are subsequently reviewed, approved and authorized in a manner commensurate to that used for the original procedure. Manaaerial and Administrative Controls Lines of authority and responsibility for the Quality Assurance Program are documented and updated, as appropriate, in the form of organizational charts, functional descriptions of departmental responsibilities or descriptions of key quality assurance positions including those providing technical support or audit responsibility. In general, the Quality Assurance Program provides that an activity is verified as being correctly performed, that Quality Assurance activities are performed independent of the individual or group directly responsible for performing a specific activity, and that Quality Assurance has sufficient authority and organizational freedom to identify quality problems; to initiate, recommend, or provide solutions to quality problems through designated channels; to verify implementation of the solutions; and to assure that further processing, delivery, installation, or use is controlled

ss until proper disposition of a nonconformance, deficiency, or unsatisfactory condition has occurred.

The responsibilities for implementation of the Quality Assurance Program, as promulgated by the Manager of Quality l Assurance / Nuclear Safety, are assigned to the President, Senior Vice President (Nuclear Operations), Senior Vice President (Engineering), Vice Presidents (BHR and PHR Operations), Assistant Vice President (Quality Programs and Assessment), General Manager of Nuclear Services, Manager of Engineering and Construction, Director of Procurement, and Vice President (Divisions). The organizations or personnel named herein and reporting to the Chairman and Chief Executive Officer (CEO), President and Chief ')perating Officer

55 (C00), Senior Vice President (Nuclear Operations), Vice Presidents (BHR and PHR Operations), Assistant Vice President (Quality Programs and Assessment), General Manager of Nuclear Services, Manager of e

Engineering and Cor,struction, Director of Procurement, Vice President (Divillons), and Manager of Quality Assurance / Nuclear Safety may assign to other organizations or personnel, the work of establishing and executing any part of the Quality Assurance Program under their cognizance, but the assigning organization or personnel

55 retain responsibility for such assignments.

The specific responsibilities for the Quality Assurance Program are described in the following paragraph!. 1.1 General j As assigned in the policy statement for the Ccrporate Quality Assurance Manual by the Chairman and CEO, the Manager l-5 Rev. 55 3/27/8tl Commonwealth Edison

of Quality Assurance / Nuclear Safety has overall responsibility for j setting policy for the Quality Assurance Program covering the design, procurement, construction and operation of the Company's nuclear generating stations. Other authorities and responsibilities are as delineated in the organization section. The President, Senior Vice President (Nuclear Operations); Senior Vice President (Engineering); Assistant Vice President (Quality Programs and Assessment); Vice Presidents (BHR and PHR Operations); Vice President (Divisions); Manager of Engineering and Construction and Director of Procurement are responsible for implementation of the Quality Assurance Programs as described herein. The Manager of Engineering and Construction reports to the Senior Vice President (Nuclear Operations) and is responsible for engineering, construction, project management, project controls, and engineering-construction technical services support activities required to perform modification work at the licensed nuclear operating stations. These responsibilities also extend to maintenance work when such work is delegated by the stations to the Engineering-Construction Department. The Manager of Engineering and Cor.struction is responsible for the maintenance and modification work performed by contractors under the supervision of the Construction Department when such work is performed at a licensed nuclear operating station. ) The Nuclear Engineering Manager reports to the Manager of

55 Engineering and Construction and is responsible for the overall engineering policies; methods and procedures; and design and procurement requirements, and is directly responsible for the design of the plant modifications for these stations.

He is also responsible for fur.-tional direction of, and assistance in, j maintenance and engineering services activities for the nuclear stations. For maintenance support, these responsibilities include providing functional direction regarding maintenance activities i during forced outages, scheduled outages and refueling operations, including establishing effective maintenance programs for controlling ALARA radiation exposure. Other services provided under the direction of the Nuclear Engineering Manager involve fire protection and the Nuclear Plant Reliability Data System (NPRDS). The BWR Projects Manager and PHR Projects Manager report to the Manager of Engineering and Construction and are responsible for coordinating and managing maintenance and modification work performed under the supervision of the Construction Department. The Projects Managers are also responsible for coordinating the engiraering aspects of the modification work designed by Engineering. The j Projects Managers' responsibilities include budget, scheduling, defining the scope of work, and resolution of issues with Engineering, Construction, the Architect Engineer, Perchasing, the station operating, maintenance, and technical staffs, and other organizations which have input to or impact on the maintenance and modification work being performed at the stations. The Projects Managers have overall responsibility to initiate those actions which are required to ensure that the assigned work is completed on schedule in accordance with technical and design requirements and authorized budgets. 1-6 Rev. 55 3/27/89 Commonwealth Edison

The Construction Manager reports to the Manager of Engineering and Construction and is responsible, through the Construction Site I Superintendent, for the supervision of maintenance and modification work performed by contractors. These responsibilities include training of personnel, monitoring and surveillance of contracted work, safety programs, radiation exposure control programs, adherence to drawing, j specification, procedure, and applicable code requirements, Quality ) Assurance Program implementation, quality control inspection, witness i point program and other activities required to complete the maintenance and modification work in accordance with applicable requirements. The System Operational Analysis Manager'and the System Materials Analysis Manager, both reporting to the Senior Vice President (Engineering), are responsible, respectively, for the testing activities of the System Operational Analysis and System Materials Analysis Departments, and have functional responsibility and control, respectively, of the System Operational Analysis and System Materials Analysis testing activities during construction and plant operations. The Manager of Quality Assurance / Nuclear Safety develops Corporate Policy for the Quality Assurance Program and verifles its implementation for the design, procurement, construction, and operation of the Company's nuclear power facilities, including related interface activities with the Nuclear Regulatory Commission, Office of Inspection and Enforcement, Region III, and the Authorized Inspection Agency. The

55 Assistant Vice President (Quality Programt and Assessment), and, in turn, the Nuclear Quality Programs Manager. directs the quality assurance activities for the design, procus'iment, construction, and operation of the Company's nuclear power facilities, including related interface activities with the Nuclear Regulatory Commission, Office of Inspection and Enforcement, Region III, and the Jurisdictional Authority.

The Manager of Quality Assurance / Nuclear Safety and the Assistant Vice President (Quality Programs and Assessment), or their designated alternate, are delegated responsibility and authority to stop unsatisfactory work and plant operations as well as further processing of unsatisfactory material during design, engineering, and construction of the plant, and during plant modification, maintenance and in-service inspection activities. Release of stop work orders shall be by the individual who placed the stop work or by a person of I higher authority in the organization placing the stop work but shall have the concurrence of the Manager of Quality Assurance / Nuclear Safety or his designee. Quality Assurance personnel shall have the respon:,1b111ty and authority to stop work on an in-process operrition/ installation as necessary, when a violation of the applicable QA Program, procedure, a I l specification or drawing is identified. Work will be permitted to proceed after implementation of necessary ccrrective action to bring the in process installation / operation into conformance has been verified 'oy Quality Assurance. If conditions which are adverse to quality and which require prompt action are found by Quality Assurance personnel at the site or Station, or other work location where work subject to the QA Program is being conducted, and required corrective measures cannot be agreed upon, the Assistant Vice President (Quality Programs and Assessment), or his designated alternate, will be notified promptly. 1-7 Rev. 55 3/27/89 Commonwealth Edison

The Nuclear Quality' Programs Manager reports to the Assistant Vice President (Quality Programs and. Assessment). The Nuclear Quality Programs Manager has responsibility for Quality Assurance activities covering ooerating, maintenance, modification, in-service inspection, administering design, procurement and construction quality assurance activities, and stores activities performed by or under direction of the station staff. He has the authority and organizational freedom to identify problems and to initiate, recommend end provide solutions. The Quality Assurance organization under this Manager is independent of the groups and individuals directly responsible for performing specific activities to which such quality assurance is applicable. The qualification requirements for the positions of Manager of. Quality Assurance / Nuclear Safety and Assistant Vice President. (Quality Programs and Assessment) include having a broad background and working knowledge on nuclear plant engineering, construction and j operating activities within Commonwealth Edison Company as well as functional interfaces with working organizations outside the Company plus having' executive capabilities to achieve goals and objectives in concert with Company policies. Also required is knowledge of Quality Assurance regulations, policies, practices and Standards and experience working in Quality Assurance or related activity in reactor design, construction or operation in a similar high technology industry. Educational requirements include, as a minimum, a baccalaureate degree or equivalent in Engineering or related science. " Equivalent" is considered to be commensurate with the factors described in paragraph 4.1 (items a-j) of ANS-3.1-1981.

55 The Manager of Quality Assurance / Nuclear Safety and the Assistant Vice President (Nuclear Programs and Assessment) shall have at le'ast four (4) years' experience in the field of quality assurance, or equivalent number of years of nuclear plant-related experience in a supervisory position, preferably at an operating nuclear plant, or a combination of the two.

At least one (1) year of this four years' experience shall be nuclear power plant-related experience in the implementation of the quality assurance program. Job requirements for the position of Nuclear Quality Program Manager include having a broad background and working knowledge of engineering, construction and operating activities within Come.onwealth Edison Company as well as having a knowledge of codes and standards applicable to power plant design, construction and operating and quality assurance principles. He also shall have supervisor and management qualities and a baccalaureate degree or equivalent in engineering or a combination of an equivalent technical discipline and work experience. The equivalent technical discipline and work experience requirement: for the Qualfty l [ Assurance Superintendents and Supervisors of Quality Assurance may I be fulfilled by a combination of education, Quality Assurance and related experience, taking into account past work performance and proficiency, totaling about five years, 1-8 Rev. 55 3/27/89 l Commonwealth Edison

The Chairman and Chief Executive Officer (CEO) promulgates corporate policy through the President and Chief Operating Officer (C00), Senior Vice President for Finance, Vice President of Corporate Planning, Vice President of Industrial Relations, Manager of Quality Assurance / Nuclear Safety, Vice President for Public Relations, and Vice President for Legal Affairs. The President and Chief Operating Officer (C00) directs the activities of the nuclear associated departments responsible for licensing, construction, testing, plant operations, nuclear and other engineering, security, training and environmental affairs. In l this capacity, he is. responsible for the activities of the Departments and Divisions concerned with the operations, maintenance and engineering of the Company's nuclear generating facilities as I well as control over Power Supply, Divisions and non-nuclear construction, production and engineering activities. The Departments and Divisions and the job position responsible for activity within each are as follows: The Senior Vice President (Nuclear Operations) has the primary responsibility of providing overall direction for the safe and efficient operation and maintenance of the operating nuclear power stations and reporting to him are: The Vice Presidents (PMR and BNR Operations) who are delegated the authority for the line management for the day-to-day operation of the nuclear stations. The Assistant Vice President (Quality Programs and

s5 Assessment) who has responsibility for management of all quality verification activities for the nuclear operations.

The General Manager of Nuclear Services who has responsibility for Nuclear Fuel Services, Production Training, Chemistry and Radwaste, Radiation Protection, Emergency Preparedness, and Management Services. The Manager of Engineering and Construction who has responsibility for providing the planning, design, engineering, and project service for construction, modification and contracted maintenance services to nuclear operations. The Vice President (or General Manager) (Divisions) is responsible for tha activities of the six Operating Divisions, and the Operating Manager. These Divisions are assigned responsibility for those activities concerned with distribution of power as well as service to customers and public relations within-tteir respective l geographical areas including operation and mairetenance and 1 inspection of electrical transmission and distribution factiitles. The Operating Manager's responsibility includes the Transmission and Distribution Construction Department which has functional responsibility and control for Division Substation Construction activities. i 1-9 Rev. 55 3/27/89 l l Commonwealth Edison L________--___

A Division Vice President is responsible for each Division. A Division Operating Manager reports to the Division Vice President. The Olvision Operating Manager is responsible for Division Substation Construction and Division Operational Analysis activities. The Director of Stores and Inventory Control is responsible for the General Harehouse mate-ial control activities, which includes the procurement, receipt, storage, and release of safety-related items and materials. Commonwealth Edison assigns to the Director of Procurement.

ss who reports to a Vice President, the responsibility for the procurement of services, spare parts, materials and equipment in accordance with the purchase requisition and contract specifications requirements and for obtaining the required quality assurance documentation for such items.

Corresponding responsibility for the procurement of nuclear fuel (including reprocessing) is assigned to the Manager of Fuel, who also reports to a Vice President. 1.2 Organization The Commonwealth Edison Company organization as related to Quality Assurance, is shown in Figures 1-0, 1-1 and 1-1-1.

ss Departmental and divisional. organizations showing the Quality Assurance function is shown in Figures 1-2, 1-2.1, 1-3 and 1-6, 1.3 Scoce Specific responsibilities for implementation of the Quality Assurance Program are assigned to the Commonwealth Edison Company organizational groups as outlined herein.

The scope of responsibilities involved in a nuclear project is divided into four Phases. Phase I - Definitions of system design and quality requirements and acceptance of the quality of design. Phase II-Verification that design and quality requirements have been met during construction. Phase III-Baseline in-service inspection; preoperational testing. Phase IV - Operation, in-service inspection, maintenance, repair, refueling, station modifications, start-up

SS testing and pre-operational testing.

1-10 Rev. 55 3/27/89 Commonwealth Edison

1.4 Enaineerina and Construction Responsibilities 1.4.1 Nuclear Enaineerina Manaaer The Nuclear Engineering Manager has overall engineering responsibility and, as applicable, assigns j responsibilities to cognizant NED (Nuclear Engineering j Department) engineers for specific modification work at the generating stations. The cognizant engineers have the responsibility to specifically supervise the electrical, mechanical, structural, instrumentation and controls and nuclear engineering activities involving the plant modifications. These responsibilities include the following: a. Review and control the design work involving the electrical, mechanical, structural and instrumentation and control designs of the NSSS vendor and,Architact Engineer to verify that appilcable Safety Analysis Report (SAR), regulatory requirements, ASME Code requirements, and design bases are properly translated into specifications, drawings, procedures and instructions. b. Review and accept the specifications and drawings for electrical, mechanical and structural material, equipment and erection work, prepared by the Architect Engineer and NSSS vendor, to verify inclusion of inspection, testing and acceptance criteria. c. Analyze bids, make purchase recommendations,

55 control expenditures, and assure that necessary quality requirements are included in purchase orders and contracts.

d. Disposition of electrical, mechanical and structural design changes. e. Review the Architect Engineer's evaluation of fabricator's and erector's detailed designs, drawings.and work instructions for reasonableness __.m and completeness. 4 f. Review and approve resolution of nonconformances ) relating to electrical, mechanical and structural j portions of the generating station. g. Establish the plans for the modification test j programs. ] h. Provide modification test acceptance criteria for i modifications designed by Nuclear Engineering. 1. Evaluate discrepant modification test results for modifications designed by Nuclear Engineering. 1-11 Rev. 55 3/27/89 Commonwealth Edison

l -1.4.1 (Continued) j. Perform detailed design activities and issue i design documents in accordance with approved procedures. k. Responsible for engineering design implementation and overseeing the Site Architect-Engineer field group (at those l locations where one is estat11shed), review and l comment on on-site contractor quality instructions and procedures, and review and approval of Ceco. Non-Conformance Reports. The Nuclear Engineering Manager has overall owner's responsibility for the Form N-3 Data Report and other CECO. N-type Data Reports, including stamping

ss responsibility for ASME Section III, Division 1 and 2, covering concrete containments.

The Nuclear Engineering Manager assigns the NA and NPT responsibilities for code adherence to the Station Manager in connection with the extension of the corporate certificates to the respective nuclear stations. 1.4.2 The Quality Assurance Coordinator assigned to the

ss Engineering and Construction Department has the responsibility to assure that the following quality assurance activities are performed.

(Also see 1.4.7.1.A) a. Development of quality procedures to be used by the Engineering and Construction Department in conjunction with the +s5 Commonwealth Edison Quality Assurance Program. b. Evaluation of contractors', including Architect Engineers', quality assurance programs. l-12 Rev. 55 3/27/89 Commonwealth Edison

p

o

/ 1.4.2 (Cont'd) c. Acceptance of only acceptable < contractors', including Architect Engineers', quality assurance programs. d. Audits of the design review system of Architect Engineer and NSSS vendors, e. Audits of off-site contr, actors, as necessary, or requested. f. Review of. purchase documents (i.e., specifications, drawings, procedures and instructions) for assurance of the ' inclusion of quality requirements. Review +55 of fabricator and erector work instructions. for inclusion of nondestructive and' electrical testing requirements. 1.4.3.The Architect Engineer is responsible to the Engineering' +55 i and' Construction Department for the mechanical, structural and electrical design of the plant and for 'the quality of that. design (except for those portions.of .that design included within the scope'of the Nuclear Steam Supply System (NSSS)).. In this context, the Architect' Engineer performs an independent evaluation of vendor proposals, designs, vendor and contractor , procedures, test reports and design reports. The Architect Engineer further performs an independent evaluation of the NSSS design..The Architect Engineer is assigned responsibility for the document distribution for Phases I, II and III of the job. 1.4.4 System Electrical Enaineerina Denartment

55 The System Electrical Engineering Department will
55 provide electrical' engineering technical assistance to the Engineering and Construction Department as requested
55 or assigned.

1-13 Rev. 55 3/27/89 f I l l l { l Commonwealth Edison

1.4.5 Construct 10n Quality-related activities in the construction area are delegated to BWR and PHR Projects Managers, the Constre' tion Manager, and the Director of Technical Services, all of whom report to the Manager of Engineering and Construction. 1.4.5.1 Construction Manaaer The Construction Department is organized with a Construction Manager, Superintendents, and Construction Field Engineers. The Construction Manager, who reports to the Manager of Engineering and Construction, assigns the cognizant Constr. 7 Superintendent the following respons' ties: a. Advisor to Nuclear Engineering and to the cognizant Projects Manager for design suitability from a construction viewpoint, b. Coordinate requests for field revisions. c. Receipt of designated items including furnishing necessary storage facilities. d. Direct'and manage contractors

ss performing maintenance and modification work which is assigned to the Engineering and Construction Department.

e. Verify conformance and completeness of contractor's installation or erection to specification requirements. f. Supervise and approve mechanical and structural construction tests. g. Coordinate and. provide assistance for electrical construction tests. The Manager of Engineering and Construction is assigned ASME Section III, Division 2, constructor responsibilities. This Manager, when applicable, has the responsibility for maintaining a Level III person on staff responsible for personnel development and qualification and for the performance to the requirements for concrete inspection, as required by rules established in Section III, Division 2, of the ASME Code. 1-14 Rev. 55 3/27/89 Commonwealth Edison 4

~ 1.4.5.2 Proiects Manaaer(s) (PHR and BHR) The Projects Manager (s) (PHR and BHR), who report to the Manager of Engineering and Construction, are delegated the authority to coordinate and manage maintenance and modification work performed under the supervision of the Construction Department. The Projects Managers are also responsible for coordinating the engineering aspects of the modification work designed by engineering which is installed by station personnel. The Projects Mar, agers responsibilities include budget, schedule, defining the scope of work, and resolution of issues with engineering, purchasing, the station operati,ng, maintenance, and technical staffs and other departments which have input to or impact on the maintenance and modification work being performed at the stations. The Projects Managers have overall responsibility to initiate those actions which are required to ensure that

ss the assigned work is completed on schedule, in accordance with technical and design requirements, and within authorized budgets.

1.4.5.2.1 Project Manaaers The Project Managers, who report to the Projects Managers are delegated the authority to direct and control the on-site project groups which have scope, schedule and budget responsibilities for modification, plant addition projects, and maintenance activities which are assigned to the Engineering and Construction Department. The Project Managers perform specific limited design activities delegated to them by the Nuclear Engineering Manager. 1-15 Rev. 55 h 3/27/89 i Commonwealth Edison

1.4.5.3 Director of Tehhnigal Services-The Director of Technical Services, who repor'ts to the Manager of Engineering and Construction, is delegated the. authority to~ direct and control the Technical. Services Department which provides technical support services to all. Engineering-and Construction departments. The Director of. Technical Services has responsibility for developing craft. labor specifications, providing estimating services,'providing drawing-management services,. coordinating the assignment: of' technical-specialists, providing Quality Control services, providing performance. assessments of contractor work, maintaining procedures,-coordinating training, and providing special studies. ( 1.4.5.3.1 Senior Supervistna-Enaineer-Specifications The Senior Supervis'ing Engineer-Specifications, who reports to the Director of Technical-Services,.is responsible for the t preparation and processing of Safety-Related and Regulatory-Related.

55 specifications for the award of service contracts for maintenance or 1

-modification work. The Senior Supervising Engineer-Specifications-1 performs technical evaluations of service contractors for placement on the Edison Approved Bidders List. 1.4.5.3.2 Ouality and Reliability Superintendent The Quality and Reliabili.ty Superintendent, who reports to the Director of Technical Services, is delegated the authority to direct and control the Engineering and Construction-Qua11ty and Reliability I group which provides Quality Control services and training program coordination to all Engineering and Construction departments. The Quality and Reliability i Superintendent administers the Edison Quality Control Inspector Qualification and Certification Program, oversees contractor Q.C. certification programs and coordinates Non-Destructive Examination Certification Programs with System Material Analysis Department. 1-16 Rev. 55 3/27/89 Commonwealth Edison ._____A_____-..A-_-

1.4.6 System Operational Analysis Denartment and System

SS Materials Analysis Deoartment The System Operational Analysis Department.and System
ss Materials Analysis Department are organized as shown in Figure 1-5.

1.4.6.1 The System Operational Analysis Manager has

ss the following responsibt'11 ties including functional control of the Division Operational Analysis Departments assigned
s5 to Construction:

i a. Participate in review of design specifications to verify the inclusion of adequate electrical testing requirements as directed. b. Prepare procedures and conduct electrical Construction tests as directed.

c.. Participate in the preparation and review of preoperational and start-up test procedures, as directed, d.

Participate in and coordinate preoperational and start-up testing, as directed. e. Maintain Commonwealth Edison Company off-site testing facilities and equipment required to fulfill the Department responsibilities. f. Provide specialized testing services and equipment analysis such as instrument and equipment calibrations (traceable to national standards). 1-17 Rev. 55 3/27/89 Commonwealth Edison

o The System. Operational Analysis' Department $55 provides' specialized field testing services through.Its technical staff specialists, standardizing and calibration services and retention of related quality assurance documentation. Also,.the Department is responsible for inspection and proof testing of electrical generation, transmission and distribution equipment. 1.4.6.2 TheSystemMaterialsAnalysisManagerhasthe

ss following responsibilities involving chemistry,-

metallurgy, nondestructive examination and vibration activities: a. Participate in review of' design specifications to verify proper selection of materials as. directed, b. Prepare procedures and conduct or contract tests as directed. c. Maintain SNT-TC-1A Level.III NDE person on

ss staff responsible for personnel and procedure development and qualification to ASME Code requirements for nondestructive examination.

d. Maintain Commonwealth Edison Company off-site testing facilities and equipment required to fulfill the Department' responsibilities. e. Provide necessary assistance and' expertise for baseline and in-service inspection. f.- Provide or contract specialized testing. services and equipment analysis such as for evaluation of materials. l The System Materials Analysis Department

ss i

provides or contracts specialized chemistry, metallurgy, nondestructive examination and ) vibration analysis services and materials j expertise through its technical staff specialists. The Company Level III NDE person j is assigned to this Department. j i 1.4.6.3 The. Quality Assurance Coordinator assigned to 1 the System Operational Analysis and System

ss Materials Analysis Departments has the responsibility to assure that the following quality assurance activities are performed:

1-18 Rev. 55 L 3/27/89 Commonwealth Edison

a. Calibration is performed on test and measurement equipment as required. b. Auditing is performed of destructive and nondestructive testing as directed. c. Nondestructive test personnel qualifications records are maintained. d. Auditing of calibration. services vendors is

55 performed.

1.4.6.3.1 General Warehouse-Stores and Inventorv Control Deoartment This Quality Assurance Coordinator is also assigned to the General.Harehouse and is responsible for assuring that safety-related materials and items are procured, stored, and released in accordance with the applicable quality requirements. Additionally, he maintains surveillance of the maintenance, storage, and release of the related quality documentation. 1.4.7 Nuclear Ouality Proarams Manaaer In the case of Engineering-Construction activities, the Nuclear Quality Programs Manager reporting to the Assistant Vice President (Quality Programs and -Assessment) is responsible for administration of the Commonwealth Edison Company Quality Assurance Program

55 Requirements and Procedures established for the design, procurement, and construction organization-related activities for the nuclear power generating stations.

Specifically, he has responsibility for the construction organization-related Quality Assurance activities and directs the Quality Assurance Coordinator assigned to q the' Engineering and Construction Department. He maintains a cognizance of the portion of the Quality ___ Assurance Program used by, or under the direction of, the station staff for operating, maintenance, modifications, in-service inspection and Stores activities to determine that it interfaces with the design, construction and station modification quality assurance phases. He, or a designee, shall serve as i liaison with the quality assurance organization of the NSSS Vendor, Architect Engineer, Authorized Inspector and contractors - as necessary - to verify i that compItance with the applicable Codes, Standards l and Regulations is met. ] 1-19 Rev. 55 3/27/89 1 i Commonwealth Edison

For application to actietties involving the operating nuclear power generating stations, including design, operation, maintenance, modification, in-service inspection, Stores and other nuclear operations-related technical and administrative activities, the Nuclear Quality Programs Manager will direct the efforts of the Station Quality Assurance Superintendents, as well as design and construction specialists and other Quality Assurance Engineers and Inspectors responsible for quality assurance activities at the nuclear generating stations and

55 Nuclear Division support departments.

The Nuclear Quality Programs Manager will regularly inform the Assistant Vice President (Quality Programs and Assessment) and the Manager of Quality Assurance / Nuclear Safety of significant quality assurance developments.and problem areas. The Nuclear Quality Programs Manager has sufficient authority to identify problem areas and require corrective action. 1.4.7.1 Site Ouality Assurance Superintendent (Enaineerino-Construction) The Site Quality Assurance Superintendents (and

55 the Station Quality Assurance Superintendents at the operating stations, for the work relating to the construction organization-related quality assurance activities) report to the Nuclear Quality
55 Programs Manager and are responsible for the quality activities within their specific department.

Each is responsible to observe and inform the Nuclear Quality Programs Manager of any deficiency involving required Safety Analysis Reports, Quality Assurance Manual Reports, design reports, construction reports and test reports. Reporting to such Superintendents, where established as site activities deem necessary, are the Site Supervisors Quality Assurance. The Site. Quality Assurance Superintendent or other established lead person, as applicable, is responsible for reviews and audits to assure that the above requirements are met and that nonconformances are resolved. Rev. 55 3/27/89 ) ) Commonwealth Edison i

A. EDP AeM ing - In addition to the i responsibilities stated herein, under ) Section 1.4.2, the Quality Assurance. Coordinator l assigned to the Engineering Department is

55 responsible for surveillance and audit of engineering activities involving construction projects and operating nuclear plants for conformance to requirements.

He maintains surveillance of required documentation of modifications activities at. operating stations where Engineering Department responsibility is involved. His responsibilities are achieved through project review, surveillance and audit

55 activities, continued monitoring and day-to-day Involvement and by support, involvement and action by the Nuclear Quality Programs Manager and by the Assistant Vice President (Quality Programs and Assessment).

B. System Ooer'ational Analysis and System Materials

55 Analv.511 - The Quality Assurance Coordinator assigned to the System Operational Analysis
ss Department and the System Materials Analysis Department is responsible for assuring that calibration procedures and records are

' maintained for Nuclear Station test and measurement equipment. He also maintains surveillance of required documentation of their respective testing and inspection activities. His responsibilities are achieved essentially in the same manner as stated for the Quality Assurance Coordinator assigned to Engineering.

55 C.

Construction Site - The Site Quality Assurance i Group will vary with the volume of quality oriented activity at the site. Generally, the number will vary from one to twenty or more; although, in the pre-construction and early and closing stages of construction, a Supervisor Quality Assurance or a Site Quality Assurance Coordinator or Engineer may perform these activities alone. l l 1-21 Rev. 55 l 3/27/89 l 1 l l Commonwealth Edison 1 l

The Site Quality Assurance Superintendent or other site Quality Assurance designee is . responsible for assuring necessary procurement requirements are provided in CECO-site procurement packages involving safety-related and ASME Code purchases, off-site vendor inspections and surveillance, surveillance of site contractor quality activities, compliance of material and equipment with procurement document requirements, maintenance of quality records filed at the site and direction of the site quality assurance group activities. These responsibilities will be achieved using Quality Assurance Engineers or Inspectors through review, surveillance and audit activities, continued monitoring and day-to-day

ss involvement.

The Site Quality Assurance Superintendent and, in turn, the Supervisors Quality Assurance reporting to such Superintendent have the responsibility that the following quality assurance activities are performed: a. Development and approval of site contractor construction quality control i procedures. b. Review and approval of site contractor quality assurance programs including site procedures. c. Advise the appropriate Engineering organization of bidder Quality Assurance capabilities when requested. d. Maintain surveillance of site contractors to verify conformance to approved quality control programs and procedures by review, surveillance and audits. j e. Assure accumulation, filing and maintenance of quality assurance ._m documents and records required for site construction by surveillance and audit. j 1-22 I Rev. 55 3/27/89 1 Commonwealth Edison

f. Review and acceotance of nondestructive test documentation. i g. Identification and maintenance of files for a site nonconforming itemt and follow-up and monitor of corrective action required for disposition of site nonconformances. j h. Maintenance of ca11 brat,1,on records for test l equipment involved in site construction activities through surveillance and audit. 1. Safekeeping of quality assurance f documentation during construction by surveillance. j. Surveillance and approval by Quality Assurance of material receiving reports including assurance required corrective actions are completed, k. Review by Quality Assurance of on-site contractor sur/cillance reports for quality problems and completion of corrective actions. 1. Quality Assurance audit of on-site contractors, m. Review and approval of site procurement packages involving safety-related and ASME Code purchases to assure necessary require-ments are provided and the proposed vendor (s) is acceptable. n. Results of electrical construction tests are reviewed. 1-23 Rev. 55

55 3/27/89 l

Commonwealth Edison

1.4.8 Station Quality Assurance Superintendent ~ The Station Quality Assurance Superintendent assigned to the operating nuclear stations reports to the Nuclear

55 Quality Programs Manager on quality. assurance activities involving operating, modifications, maintenance, in-service inspection and Stores activities involving

+55 operating nuclear power stations. The respective Quality Assurance Engineers or Inspectors assigned to the station report to the Station Quality Assurance Superintendent. A. Quality Assurance Engineers or Inspectors assigned

55 to a station to cover operating activities have authority and responsibility for the surveillance and audit of:

a. The preparation and revision of the station procedures for administration and operations. b. Implementation of the Operations portion of the Quality Assurance program. c. The completion of documentation showing that the required inspections and tests were performed. d. The completion of reported corrective action. e. The incorporation of approved engineering changes into station operating procedures. B. Quality Assurance Engineers and Inspectors assigned

55 to the station to cover maintenance, modifications, in-service inspection and Stores activities have authority and responsibility for surveillance and audit of:

a. Implementation of the modification and maintenance portion of the Quality Assurance Program. b. The preparation and revision of the Station Procedures for the modification and maintenance. c. The completion of documentation showing that the required inspections and tests were performed for modification, maintenance and mataarial receipts. They shall also review and +55 approve receiving inspection documentation. 1-24 Rev. 55 3/27/89 Commonwealth Edison I

d. The proper and satisfactory completion of modification, maintenance and reported l corrective action. They shall also review and

55 l

approve such completion and corrective action. l e. The incorporation of approved engineering changes into maintenance and operating i procedures. f. Completion of ASME Code requirements. g. In-service inspection and Stores activities. h. Adherence to Technical Specification requirements where involved with modification, maintenance and in-service inspection activities. 1.5 Nuclear Operations Responsibilities Nuclear Stations Division 1.5.1 Vice Presidents (BWR and PHR Ooerations)

55 The Commonwealth Edison Company production stations are divided into two Divisions - Fossil and Nuclear with the Nuclear Stations Division being divided into two groupings, one consisting of the three Pressurized Water Reactor nuclear stations and the other of the three Boiling Hater Reactor nuclear stations.

The respective Vice Presidents in charge of the Fossil Stations Division and of each grouping of stations in the Nuclear Division are responsible for the safe and reliable operation and maintenance of the plant assigned to them.

55 The Vice Presidents (BWR and PHR Operations) report to
55 the Senior Vice President (Nuclear Operations) and have responsibility for managing the nuclear generating stations associated with their respective station
ss grouping.

1 The_Vice Presidents (BWR and PHR Operations) are

5s I

responsible for approval of requisitions for the procurement of parts, components and materials, support services and work assistance functions involving j maintenance, modifications and special tasks from I vendors and contractors. The Manager of Engineering and l

55 Construction has responsibility for like approvals for the Engineering and Construction organization I

activitities involving the nuclear generating stations. l 1 1 1-25 Rev. 55 ) 3/27/89 i Commonwealth Edison

1.5.1.1 General Manager (BWR and PHR Ooerations) 555 ' The two General Managers (BWR and PWR Operations) are +55 shown in Figure 1-6. These General Managers report to the respective Vice Presidents (BHR and PWR Operations)

55 and each has responsibility, as assigned, for functionally directing their assigned nuclear generating stations, through the respective Station Manager, in a safe and efficient manner and in accordance with Company procedures,,NRC Technical Specifications and governmental regulations.

As assigned by the Vice President, they have functional control responsibility for coordinating station policies, providing support to operating station personnel, coordinating unit outages with Power' Supply, j and providing functional direction to the Station 4 Managers regarding day-to-day matters. They also act on the behalf'of the cognizant Vice President for other items as delegated to them and during periods when the cognizant Vice President is unavailable. They are also functionally responsible for obtaining and authorizing the use of services, or for required liaison or~ interface with other Commonwealth Edison Company departments such as: Accounting, Nuclear

ss Engineering, Construction, Nuclear Services, Quality Programs and Assessment (including Nuclear Licensing),

Industrial Relations, Quality Assurance / Nuclear Safety, System Materials Analysis and System Operational Analysis. Where assigned, they provide liaison between the Regional Nuclear Regulatory Commission's Director of the Office of Inspection and Enforcement and the respective Nuclear Division Departments. They are involved functionally, through the Station Manager of each assigned station, in the direction of

55 such activities as operations, maintenance, station security, refueling, authorization of modifications performed at the Station, performance monitoring and investigation, compliance with procedures, regulations l

and licenses, personnel selections, training and related activities. Their responsibilities include coordinating operating and maintenance policies and providing functional direction regarding day-to-day matters. They maintain industry contacts with nuclear stations i of other companies and transmit information from them regarding operating problems to Commonwealth Edison's Nuclear Stations. 1-26 Rev. SS 3/27/89 Commonwealth Edison I l m____________ i

l 1.5.1-.1 General Manaaers (BHR and PWR Ooerations) (Cont'd)

ss-For common equipment and system problems, they
ss communicate such problems among stations in a timely manner.

They have Deviation Report events, Quality Assurance audits, NRC inspection reports and other significant events and functions reviewed for trends, effects on other units and corrective actions. 1.5.1.2.1 STATION MANAGER Each nuclear generating station is managed, through the Production Superintendent, the Technical

ss Superintendent, the Services Director and the Industrial Relations Supervisor, respectively, by a l

-Station Manager wLo is responsible for the management of the station including industrial relations,. planning, coordination, direction of the operation, maintenance, refueling and technical activities. The Station Manager is responsible for Phase III and IV and compilance with the Station's NRC Operating license, government regulations, ASME Code requirements and the Company Quality Assurance-Program. He also authorizes the use of procedures contained in the Station Procedures Manual, and is responsbile for final approval and distribution of station reports. He may delegate these responsibilities as appropriate to the appropriate Superintendents. Prior to issuance of the operating license, the Production organization provides personnel to support activities of an operating nature where the preoperational test activities, including reviews of test data, are assigned to a separate organization in Projects at the construction site. Repair and equipment maintenance needing technical review for substitution of equipment are reviewed by the Station Technical Staff and completed as maintenance activities under station management. j He supervises the Station's on-site review function as provided in the Administrative Section 6.0 of the Technical Specifications. During periods when the Station Manager is unavailable, he shall designate this responsibility to an established alternate who satisfies the ANSI N18.1 experience requirements for plant manager. I 1-27 Rev. 55 l 3/27/89 Commonwealth Edison

l 1.5.1'.2.1.1 Jndustrial Relations Suoervisor The Industrial Relations Supervisor i reports to the Station Manager and i performs various personnel, employment,

SS safety and industrial hygiene activities.

{ 1.5.1.3.0 Production Superintendent, Reports to the Station Manager. Manages operating, maintenance and work planning

55 activities including the day-to-day operations of the station, both during operating and during outages.

The Production Superintendent authorizes approved modifications to the

SS Station after the issuance of an operating license and completion of preoperational testing.

He, or his designee, forwards requests for modifications to the Project

55 Hanager for transmittal to the Nuclear Engineering Department. Also, the Production Superintendent is responsible for controlling the in-plant work of non-station personnel.

Reporting to him are the Assistant Superintendent of Operating, Work Planning +55 Assistant Superintendent and Assistant Superintendent of Maintenance. 1.5.1.3.1 Assistant Superintendent of Operatina

5S Responsibility for the day-to-day operating and refueling activities for the station is delegated to the Assistant Superintendent of
SS Operating.

Reporting to him are the Station Operating Engineers and Shift Engineers who have reporting to them the Fuel Handling

ss Foremen, Procedures Group, Radwaste Coordinator and Foremen, Station Control Room Engineers, Shift Foremen, and the Stationmen Foremen.

1.5.1.3.1.1 Ooeratina Enaineers. The Operating Engineers are responsible for the operation of the mechanical and electrical equipment and certain common plant systems, such as fuel handling and radioactive waste processing, assigned to them by the Assistant Superintendent of Operating. They are +55 responsible for recommending maintenance for such equipment and for authorizing functional acceptance tests to be conducted by Operating and Technical Staff personnel. 1-28 Rev. 55 3/27/89 Commonwealth Edison

1.5.1.3.1.2.Shiftd naineer The Shift Engineer on duty is responsible for operating the plant in compliance with the station Operating License and the station operating procedures. During his shift, the Shift Engineer is in charge of the entire plant operation and is responsible for the plant being operated in a safe,and reliable 4 condition. He reports to the Assistant Superintendent of Operating. He

ss i

receives direction from the Operating Engineers. 1.5.1.3.2 Assistant Superintendent of Maintenance

ss The Assistant Superintendent of Maintenance
ss reports to,the Production Superintendent and is responsible for directing plant modifications and the maintenance, including repair, of the mechanical and electrical equipment including instrumentation.

His responsibility includes planning work, providing on-the-job training of maintenance personnel, maintaining calibration listing for maintenance, arranging for the maintenance work and its inspection to be performed and initiating requisitions for the procurement of tools, materials, equipment and parts'from vendors and services from contractors. Reporting to him are the Master Mechanic, Master Instrument Mechanic, Master

ss Electrician and Maintenance Supervisor.

1.5.1.3.2.1 Master Instrument Mechanic

ss The Master Instrument Mechanic is responsible for calibrating, maintaining
ss and repairing instrumentation at the station. His responsibility includes planning work, providing on-the-job training of instrument personnel, setting up instruments for tests, maintaining listing of calibrated instruments, arranging for the instrument maintenance work and its inspection to be performed and initiating requisitions for the procurement of instruments and parts from vendors and services from contractors.

The Master Instrument Mechanic reports to the l Assistant Superintendent of Maintenance.

ss 1-29 Rev. 55 3/27/89 1

l Commonwealth Edison

1.5.1.3.2.2 Master Mechanic The Master Mechanic is responsible for maintaining and repairing mechanical equipment and structural equipment at the station. His responsibility includes planning work, providing on-the-job training of mechanical

maintenance

$s5 personnel, arranging for mechanical maintenance work and its inspection to be performed, and initiating requisitions for the procurement of mechanical and structural parts and components from vendors and services from contractors. The Master Mechanic reports to the Assistant Superintendent of Maintenance.

55 1.5.1.3.2.3' Master' Electrician The Master Electrician is responsible for i

maintaining and repairing electrical equipment at the station. His responsibility includes planning work, providing on-the-job training of electrical maintenance work and its inspection to be performed, and initiating' requisitions for the procurement of electrical parts and components from vendors and services from contractors. The Master Electrician reports to the Assistant Superintendent of

55 Maintenance.

1.5.1.3.3.0 Work Plannino Assistant Superintendent

ss The Work Planning Assistant Superintendent
55 is responsible for preplanning outages, for coordinating and administering the execution of station outages, including providing schedules and monitoring progress, and for conducting post-outage reviews.

1.5.1 4.0 Technical Superintendent

55 The Technical Superintendent reports to the Station Manager and is responsible for the day-to-day Chemistry, Health Physics, Technical Staff, Quality Control and Regulatory Assurance
ss Departments' activities at the station.

The Supervisors of the respective departments report to him. 1-30 Rev. 55 3/27/89 Commonwealth Edison

] (.

55 i

1.5.1.4.1 Technical Staff Suoervisot l The Technical Staff Supervisor reports to the

55 Technical Superintendent and provides technical support for plant operations, refueling, maintenance, modifications and in-service

' inspection and evaluates process data and equipment performance and adequacy of station procedures. He has the responsibilities and

ss authority as described in Section 6.0 of the Technical Specifications for implementation of the on-site review function.

He is also responsible for the following: a. Witnessing of assigned testing for verifying completion of modifications and equipment maintenance, b. Verification of incorporation of approved engineering changes into station. maintenance and operating procedures. c. Verification of completion of reported corrective action. 1.5.1.4.2 Ouality control suoervisor

ss The station Quality Control-Supervisor reports to the Technical Superintendent and

+55 is responsible for the quality control activities at the Station such as: reviewing drawings, specifications, Maintenance / Modification Procedures and requests for purchase for inclusion of applicable quality requirements; performing receiving inspection for ASME and safety-related incoming materials and items and inspection of fabrication and installation activities; and having nondestructive examination and other testing performed as required. 1.5.1.4.3 Chemistrv Suoervisor

ss The Chemistry Supervisor reports to the Technical Superintendent and is responsible
55 for directing Chemistry and Radio Chemistry activities.

e 1-31 Rev. 55 3/27/89 Commonwealth Edison 1

1.5.1.4.4 Health Physics Suoervisor CSS The Health Physics Supervisor reports to the Technical Superintendent and is

55 responsible for directing the Health Physics activities.

He is responsible for the implementation of a Station Radiation Protection Program to maintain radiation

55 exposures as low as reasonably achievable (ALARA).
55 1.5.1.4.5 Reaulatory Assurance Suoervisor
55 The Regulatory Assurance Supervisor reports
55 to the Technical Superintendent and is responsible for tracking of commitments; authorizing and analyzing LER's and DVR's, including trending; directing the process
55 of preparing and approving correspondence, reports and responses involving Deviation Reports (DVR's) and Licensee Event Reports
55 (LER's), Quality Assurance deficiencies, NRC correspondence and responses, OPEX's, Technical Specification changes, FSAR updates, and INPO and Authorized Nuclear
55 Inspection evaluations, and monitoring regulatory compliances and performance, 1.5.1.5 Services Director
55 The Services Director reports to the Station Manager and manages intra-station services and coordinates services provided to the station
ss from outside the station. Reporting to him are the Stores, Training, Office, Accounting, Security and MIS (Management Information System) Supervisors.

1-32 Rev. 55 I 3/27/89 Commonwealth Edison

1.5.1.5.1 Stores Suoervisor

ss 1

The station Stores Supervisor r'eports to the Services Director. The station Stores

ss Supervisor. receives functional direction, which includes all Stores Instructions, from the Director, Stores and Inventory
ss Control Department.

The Stores Supervisor is responsible for the administration of the Station Storeroom including all procurement, receiving inspection, storing and issuing of capitalized spare parts, materials, supplies and equipment. His responsibilities include coding of all stocked items; verifying the receipt of Quality Assurance documents specified in the procurement documents for spare parts, welding materials, other materials and equipment; maintaining inventory records for all stocked items at the station; and complying with special handling and storage instructions. l 1.5.1.5.2 office Suoervisor

ss The Office Supervisor reports to the
ss Services Director and is responsible for directing the activities of the station's clerical staff and for maintaining files of quality assurance documents assigned to him.
ss 1.5.1.5.3 Security Suoervisor
ss The Security Supervisor reports to the.
ss Services Director and is. responsible for directing the station's security plan activities and supervising the on-site

} security activities.

ss 1.5.1.5.4 Trainina Suoervisor i

The Training Supervisor. reports to the

ss Services Director and is responsible for the training and retraining of operating, technical support and maintenance personnel.

His responsibility includes planning, scheduling, preparing, presenting and documenting completion of training. [- 1-33 Rev. 55 3/27/89 Commonwealth Edison

v. 1.6 Ouality Proarams and Assessment 1.6.1 Assistant Vice President (Ouality Proarams and Assessment) l The Assistant Vice President (Quality Programs and Assessment) reports to the Senior Vice President (Nuclear Operations) and has responsibility for management of all Quality Verification activities for the Nuclear Operations Division. The primary responsibility of the Assistant Vice President (Quality Programs and Assessment) is to direct the conduct of the Nuclear Quality Program and Independent Safety Engineering Group activities, through the Nuclear Quality Program and Safety Assessment Departments. In addition, the Assistant Vice President implements a technically expert, integrated Quality Verification Program focused on the quality of overall nuclear performance including planning, implementation, corrective actions, and review for effectiveness of all Nuclear Operations Program activities related to the safe and reliable generation of nuclear power. This Quality Verification Program is implemented through the integration of the activities of the Nuclear Quality Program, Safety Assessment, Performance Assessment, Nuclear Licensing and Performance Improvement Departments. The Assistant Vice President also directs

ss the activities of a staff which develops programs, plans, information management systems, and training programs to support the activities of Quality Programs and Assessment Departments.

i 1.6.1.1 Nuclear Licensina Manaaer The Nuclear Licensing Manager reports to the Assistant Vice President (Quality Programs and Assessment) and has responsibility for acquiring i and maintaining Nuclear Regulatory Commission (US NRC) and Illinois Department of Nuclear Safety (IDNS) licenses and permits. The Nuclear Licensing Manager assures timely reporting on matters related to these licenses and permits to appropriate levels of management and supports the integration of these activities with related i quality verification activities in the Quality Programs and Assessment Group. __m., I l-34 Rev. 55 3/27/89 ) l ) Commonwealth Edison

1.6.1.2 Performance Assessment Manaagt The Performance Assessment Manager reports to the Assistant Vice President (Quality Programs and Assessment) and directs non-reguitory performance assessment activities within the nuclear division and supports the integration of these activities with related quality verification activities in the Quality Programs and Assessment Group. He maintains a staff of highly qualified technical experts in key areas, and through their efforts, identifies areas of weakness and recommends necessary corrective actions. He coordinates followup to evaluate the effectiveness of corrective actions in addressing identified weaknesses and ensures that appropriate information is communicated to other potentially affected nuclear stations. He provides advice and { technical guidance for the resolution of j generic and plant specific performance problems. i 1.6.1.3 Nuclear Ouality Proarams Manaaer The Nuclear Quality Programs Manager reports to the Assistant Vice President (Quality Programs and Assessment) and is responsible for administration of the Commonwealth Edison Company Quality Assurance Program Requirements

55 and Procedures established for the operating phase of nuclear power generating stations.

These activities include administration of the Quality Assurance Program for design, operation, maintenance, modification, in-service inspection, Stores, and other nuclear operations related technical and administrative activities. Specifically, he will direct the efforts of the Site and Station Quality Assurance Superintendents, as well as design and construction specialists and other Quality Assurance Engineers and Inspectors responsible for quality assurance activities at the nuclear generating stations and Nuclear Division support departments. The Nuclear Quality Programs Manager will regularly inform the Manager of Quality Assurance / Nuclear Safety of significant quality assurance developments, activities and problem areas. He has the authority and organizational freedom to identify problems, to initiate, recommend and provide solutions, and initiate work stoppage actions as deemed needed. The Quality Assurance organization is independent of the groups and individuals directly responsible for performing specific activities to which such quality assurance is applicable. 1-35 Rev. 55 3/27/89 Commonwealth Edison

+, 1.6.1.4 Saf'ety Assessment Manaaer The Safety Assessment Manager reports to the Assistant Vice President (Quality Programs and Assessment) and directs the oversight of assessment activities related to operating experience developed from inside and outside the Company in order to support Nuclear Operations in identifying actions to improve nuclear station performance and, through the Onsite Nuclear Safety Groups, to review and evaluate station safety-related operating events and observe operating and maintenance activities in the station. The Onsite Nuclear Safety Groups (ONSG's) perform the role of Independent Safety Engineering Groups (generically referred to as ISEG's) which are required by NRC regulation at all nuclear stations licensed after the Three Mile Island incident. The Manager also directs the activities of the onsite nuclear safety support group, which

SS-serves as the ONSG offsite group. The support group provides technical assistance and coordinates resources for the ONSG's.

1.6.1.5 Performance Improvement Manaaer The Performance Improvement Manager reports to the Assistant Vice President (Quality Programs and Assessment) and directs the acquisition of external performance assessment information and provides recommendations and assistance to nuclear station and corporate management to promote improved station and corporate performance. The Performance Improvement Manager assures that industry and generic. regulatory issues are adequately reviewed and monitored and advises corporate management of impending actions, tracks operating activities i to detect possible declining trends, investigates selected events to identify root causes and recommend corrective actions, and provides support to other Quality Programs and Assessment Departments. 1-36 Rev. 55 3/27/89 1 1 Commonwealth Edison

E <T l'7 NUCLEAR SERVICES SUPPORT RESPONSIB L1 TIES 1.7.1 General' Man'aaer of Nuclear Services The General Manager of Nuclear Services,_who reports to the' Senior Vice. President-(Nuclear Operations), directs ~ and controls the activities of the Nuclear Services Department, including' health physics, chemistry, radioactive waste management and emergency preparedness for the Nuclear: Operations area. t He'also-is delegated the authority to provide timely technical support to the Nuclear Operations area for training, nuclear fuel services, and management services. In the execution of this delegated authority he.will be responsible to the Senior Vice President (Nuclear Operations) for organizing, planning and executing the elements of nuclear support services.in an effective.and' efficient manner. The General Manager of Nuclear Services is the primary Company participant in industry. groups and task forces in the areas of wast + compacts and low level waste disposal.

1. 7.1. 1 froduction Trainina Manaaer The Production Training Manager, who reports to the General Manager of NuclearaServices, i

provides direction and control for the activities of the Production Training Department (PTD),~1ocated at the' Production.

55-Training Center.

Production training includes four major working groups. These are Operations Training, Technical and Maintenance Training, Program Development, and Support Services. The PTD develops and periodically revises training programs designed to meet the overall needs of the Nuclear Operations area. The PTD y also coordinates training programs for i production management, and develops and -implements instructor training programs. To ensure that the training effort is fully effective, the PTD also designs and implements training program evaluation plans.. l. 1.7.1.2 Director of Manaaement Services The Director of Management Services, reporting to the General Manager of Nuclear Services, directs and controls'the activities of the i Management Services Department including Management Information Services, performance analysis, office management, minority business, and special services. The department is a . source of general administrative guidance and services to the entire Nuclear Operations area. In addition, the Management Services Department provides daily staff support to the Senior Vice President (Nuclear Operations) and to the nuclear stations. 1-37 Rev. 55 Commonwealth Edison 3/27/89 i

1.7.1.3 Ng lear Fuel Servirm Manaaer The Nuclear Fuel Services Manager _ reports to the General Manager of Nuclear Services and is delegated the authority for the direction and ' control of the Nuclear Fuel Services Department (NFS). NFS provides in-core nuclear fuel management, safety analysis, and technical i support to station personnel and other departments regarding fuel and other reactor core issues. The NFS organization includes Computer Methods Development, Nuclear Design, Safety Analysis, Plant Support, Fuci Reliability, and Core-Materials Technology. The Department is accountable for the development of analytic methods and for the performance of reactor neutronic, transient and safety analysis studies to support licensing and plant operations.

1. 7.1. 4 Emeraency Preparedness Director The Emergency Preparedness Director, who reports to the General Manager of Nuclear Services, supervises the activities of the Nuclear Operations Emergency Preparedness Department.

This Department has control of the i environmental radiological and meteorological monitoring programs; the Nuclear Station Emergency Planning (GSEP) program; and the maintenance of six emergency response facilities and six warning siren networks.

ss Additionally, the Emergency Preparedness Director performs a liaison function between Illinois, Iowa, and Hisconsin emergency services groups and the Vice Presidents (PHR and BWR Operations).

1.7.1.5 BAdiation Protection Director The Radiation Protection Director reports to the General Manager of Nuclear Services and is delegated authority for the development, implementation, and control of Company radiation standards and procedures and the corporate ALARA program. Additionally, the Radiation Protection Director provides functional control over the station Radiation Protection Departments. 1.7.1.6 Chemistry Services Director l The Chemistry Services Director, who reports to the General Manager of Nuclear Services, supervises a staff which supports the nuclear stations in the areas of analytic chemistry, chemical engineering, radiochemistry, process chemistry control, radioactive wastes, and applicable computer software. 1-38 Rev. 55 3/27/89 Commonwealth Edison

Direrstor Cargrate Segurity - Nyclear legrity 1.8 r This Director for Nuclear Security reports to the President and

55 Chief Operating Officer.

The Director is responsible for insuring that security programs at the nuclear power stations effectively meet all commitments to, and the regulations of, i the Nuclear Regulatory Commission. 1.9 System Power-Sucolv Deoartment The System Power Supply Manager reports to the President and

55 J

Chief Operating Officer, and is responsible for managing the j bulk power system with the objectives of safe operation, i reliable service and efficient utilization of Company-owned i production facilities. 1.9.1 The System Power Supply Manager has the following

ss responsibilities:

a. Scheduling power generation. b. Purchase and sale of power from and to other utilities. c. Coordinating the operation of the Commonwealth system with the Mid-America Interconnected Network

55 and other interconnected utilities.

d. Final scheduling of outages for generating stations for corrective and preventative maintenance. i 1.10 Stores and Inventory Control Denartment

SS The Director for this Department has the following
55 nuclear-associated Stores activities responsibilities:

a. Control of spare parts inventory; b. Coordinating procurement of spare parts and materials and assuring that technical and quality assurance requirements are specified in procurement documents; and c. Liaison with company stations and departments, manufacturers.and other utt11 ties on spare part matters.

55 The Support Services staff of this Department, in particular, review station purchase requisitions for safety and ASME Code related spare parts, material and equipment to assure that requirements for Quality Assurance are specified as required and that Stores Code Numbers are assigned to spare parts to be stored at the station.

1-39 Rev. 55 (3/27/89) Commonwealth Edison i

+ 1.11 Ouality Assurange/Nurdpar Safety Policy and Oversicht Oeoartment 1.11 Manaaer of Ouality Assurance / Nuclear Safely The Manager of Quality Assurance / Nuclear Safety reports to the Chairman and CEO. This Manager manages the Off-Site Review and Investigative Group, the Central Committee for Quality Assurance Policy, and the Off-Site Audit Group. The primary responsibilities of the Hanager of Quality Assurance / Nuclear Safety are to: a. Develop and implement Corporate Policy for quality

55 assurance and nuclear safety activities for the design, procurement,. construction, and operation of the Company's nuclear power facilities and interface activities with the Nuclear Regulatory Commission, Office of Inspection and Enforcement, Region III, and the Authorized Inspection Agency.

b. Promptly report any unsafe plant conditions or practices to the Chairman and CEO of the Company. c. Assure that findings resulting from off-site audits and recommendations of the Off-Site Review Group

ss are satisfactorily resolved.

d. Assure implementation and consistency of the Quality Assurance Program through control of the

ss Quality Assurance Manual.

i e. Review the various phases of nuclear safety (design, construction, operation, and maintenance) to provide for integration of all safety-related considerations, i f. Initiate recommendations to improve safety at j nuclear plants. g. Establish specific audit training requirements and issue auditor and lead auditor certification for individuals who have successfully completed those

SS

_ auditor training programs and met Standards requirements. h. Establish qualification requirements and issue qualifications and/or certifications to such requirements, as required by Standards and Regulatory requirements, for individuals performing i Quality Assurance inspection, surveillance and audit activities. j 1-40 Rev. 55 (3/27/89) Commonwealth Edison

.o 1.11.1.1 Superintendent of Off-Site Reviec l The Superintendent of Off-Site Review reports l to the Manager of Quality Assurance / Nuclear Safety and is appointed by the Manager of Quality Assurance / Nuclear Safety with approval by the Chairman and CEO. The Off-Site Review Participants are appointed by the Superintendent of Off-Site Review. Each operating nuclear station has two reviewers assigned to it in the Off-51'te Review Group. They are identified as the " Senior l Participant", assigned full time to the designated station, and as the "Other Participant". Primary responsibilities of the Superintendent of Off-Site Review are to: a. Provide direction for the review and investigative function. b. Appoint the Senior Participants and their alternates. c. Select other participants for the function, as found necessary. d. Select participants to provide appropriate

55 interdisciplinary coverage for the subject under review.

e. Independently review the findings and recommendations of the participants to the review. f. Approve reports of the Off-Site Review and make recommendations as appropriate. g. Approve and report, in a timely manner, findings of noncompliance with NRC requirements to the Station Manager, Vice President (BHR or PHR Operations), Manager of Quality Assurance / Nuclear Safety, Assistant Vice President (Quality Programs and Assessment), and the Senior Vice President (Nuclear Operations). 1.11.1.2 Superintendent of the Duality Assurance Central i Committeg I I The Superintendent of the Quality Assurance Central Committee reports to the Manager of Quality Assurance / Nuclear Safety and is appointed by, and reports to, the Manager of Quality Assurance / Nuclear Safety with approval by the Chairman and CEO. 1-41 Rev. 55 3/27/89 Commonwealth Edison

F. .s L The primary responsibilities of the Superintendent of' the Quality Assurance Central Committee are to: l a. Develop strategic Corporate Quality Assurance policy for the design, procurement, construction, and operation of the Company's nuclear and fossil power facilities. b. Develop and obtain approval of inter-departmental agreement documents to facilitate the implementation of Quality Assurance and Nuclear Safety policies. c. Anticipate potential Quality Assurance problem areas through review of both Company internal and external documentation. d. Maintain, in an up-to-date condition, the Quality Assurance Manual for both the nuclear and fossil divisions. e. Assist Company personnel in the use and interpretation of the Quality Assurance Manual. f. Develop and maintain the training program

55 requirements and issue certification documents for all personnel filling the position of an audit function, g.

Report difficulties in the implementation of the Quality Assurance Program or Quality Assurance Policy developed by the Central Policy Committee directly to the Manager of Quality Assurance / Nuclear Safety. 1.11.1.3 Superintendent of Off-Site Audits The Superintendent of Off-Site Audits reports to the Manager of Quality Assurance / Nuclear Safety. The responsibilities of the Superintendent of Off-Site Audits are: a. Managing the corporate off-site vendor audit program, b. Managing the Off-Site Audit Program of the various organizations of the Nuclear and Fossil Stations Divisions to obtain an independent assessment of the implementation of the Quality Assurance Programs for these two Divisions. c. Managing the Off-Site Audit Program of the Nuclear Steam Supply System (NSSS) Vendors and Architect Engineers (AE). 1-42 Rev. 55 3/27/89 Commonwealth Edison

i 1.11.1.3.1 Nuclear Fuel Fabrication fnsoector The Nuclear Fuel Fabrication In~spector reports to the Superintendent of Off-Site Audits and has the responsibility for surveillance inspection and audit of fuel +55 fabrication at vendor's plant, overview of the fuel control at the nuclear stations and keeping abreast of fuel assembly problems and concerns., 1.12 Purchasina Responsibilities l l 1.12.1 Hanager of Fuel The Manager of Fuel is responsible for Commonwealth's procurement of nuclear fuel to specifications furnished by the Nuclear Fuel Services Department. He reports to a Vice President on, matters involving such fuel.

55 2.0 Division Ooerations Responsibilities 2.0.1 Substation Construction Department The Substation Construction Department performs electrical modification at nuclear generating stations as directed by the Production Superintendent, or designee, or the Engineering and Construction Department u

Construction Superintendent, or designee, and in accordance with the provisions of this Quality Assurance Manual. Substation Construction Site Specific Procedures are used to control specific procesres and procedures unique to electrical construction and installation. i 4 1-43 Rev. 55 3/27/89 Commonwealth Edison

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2. QUALITY ASSURANCE PROGRAM 2.1 General j

The Commonwealth Edison Company has extensive experience with the development, scheduling, design, construction and operation of electric generating facilities. It has pioneered in commercial nuclear power. Commonwealth Edison Company and its consultants and vendors have established designs and specifications for compliance with applicable regulations, ASME Code and National Standards to assure installations of utmost safety and reliability. Commonwealth Edison Company has attained qualified equipment vendors and contractors through experience, evaluation at vendor plants l and site surveillance during plant erection. These efforts provide assurance that compliance with applicable design specifications and codes is maintained and a high, level of reliability is achieved. 2.2 Policy It is the policy of Commonwealth Edison Company to assure a high degree of functional integrity of the equipment, structures and safety-related systems of its nuclear generating facilities, the performance of which are essential to the prevention of nuclear accidents that could cause undue risk to the health and safety of the public, or to the mitigation of the consequences of such accidents in the unlikely event they should occur. These systems, equipment, and structures will be identified, designed, fabricated, erected, tested and operated to the criteria and requirements of ASME Boiler and Pressure Vessel Code Sections III and XI, as referenced in the SAR applicable to a specific unit at the time of engineering, construction and major modifications, Appendix B to 10CFR50, Subpart H to 10CFR71, and the mandatory requirements of ANSI /ASME NQA-1-1983 (Regulatory Guide 1.28 Rev. 3 Dated 8/85) with the provision that CECO suppliers / vendors maintain a quality assurance program which satisfies ANSI /ASME, NQA-1-1986 or the ANSI /ASME N45.2 series of standards, ANSI N45.2 Standards not covered by ANSI /ASME NQA-1, and N18.7 Standards.

51 The commitments to Regulatory Guides and Standards shall apply to each respective station as listed below.
st Also, bclmmonwealth Edison commits to comply with 10CFR

~~ Part 21 " Reporting of Defects and Noncompliance" and with the Regulatory position of the following Regulatory Guides and the requirements of the following ANSI Standards as listed for each station. l 2-1 Rev. 51 7/07/88 I f Commonwealth Edison

I. Dresden, Quad Cities and Zion Nuclear Power Stations 1.28 - Rev. 3, 8/85; 1.30 (Safety Guide 30 - 8/72); 1.33 Ma (Safety Guide 33 - 11/72); 1.37 3/73; 1.38 - 3/73; 1.39 - 3/73; 1.54 - 6/73; 1.8 (Safety Guide 8 3/71); ANSI N45.2.8-74 (Draft 2, Rev. 3, 4/74); ANSI N45.2.5-73 9 Draft 3, Rev. 1, ya 1/74) II. LaSalle County Nuclear Power Station,, 1.28 - Rev. 3, 8/85; 1.30 - Rev. O, 8/72; 1.33 - Rev. 2; 1.37 MR - Rev. O, 3/73; 1.38 - Rev. 2; 1.39 - Rev. 2; 1.54 - 6/73; 1.8 - Rev. 1-R; 1.94 - Rev. 1; 1.116 - Rev. 0-R, 6/76 III. ' Byron and Braidwood Nuclear Power Stations na 1.28 - Rev. 3, 8/85; 1.30 - Rev. O, 8/72; 1.33 - Rev. 2; 1.37 I - Rev. O, 3/73;-1.38 Rev. 2; 1.39 - Rev. 2; 1.54 - 6/73; 1.64 - Rev. 2; 1.8 - Rev. 1-R; 1.94 - Rev. 1; 1.116 R, 6/76 en Exceptions or alternatives to this Topical Report for specific plants identified in the Safety Analysis Report or Technical Specification will take precedence over commitments in this Topical Report. It is also the policy of Commonwealth Edison Company to assure a high degree of functional integrity for its generating facilities so as to achieve high availability of these facilities for the production of electrical power and to maintain overall quality levels which will achieve the fotogoing in a safe, effective and economic manner. The Quality Requirements and Quality Procedures of the Company Quality Assurance Program Manual (see Appendix A for Program Manual Index) as described herein, document the written policies and procedures of the Program and are augmented by other written Depart-ment and Station procedures and instructions. In the Quality Assurance Department controlled Quality Assurance Department instructive, directive and procedural type documents are used to further explain in specific detail certain department activities as deemed needed. Such documents may cover items such as training, training program, review of procurement documents, personnel qualification and certification, maintenance and updating of ASME Code information on the computerized Quality Approved Bidders List, etc. In addition, Site Quality Assurance Departments may have controlled Site instructions to provide detailed explanations and methodologies for implementing the Quality Requirements and Quality Procedures, and to provide instructions for other site quality activities as necessary. 1 2-2 Rev. 51 7/7/88 Commonwealth Edison j

\\ i The quality assurance programs of Commonwealth Edison Company, Architect Engineers and Nuclear Steam Supply System vendors include the requirements of ASME Section III Article NCA-4000, the quality assurance criteria for nuclear power plants of Appendix B to 10CFR50 " Quality Assurance Criteria for Nuclear Power Plants," and the mandatory requirements of ANSI N45.2, " Quality Assurance Program Requirements for Nuclear Power Plants"; and ANSI N18.7, " Standards for Administrative Control for Nuclear Power Plarits." The requirements are implemented by means of detailed quality procedures delineating th: specific methodology to be used. In addition, individual contractors', fabricators' and vendors' Quality Assurance

SS programs will include the applicable portions of the Code, Standards and Appendix B as they affect the total program.

The overall Commonwealth Edison Company quality assurance program, as a minimum, provides for engineering design control, audit and surveillance of on-site contractors and off-site vendors, surveillance and audit of the performance and quality assurance procedures of the Architect Engineer and Commonwealth Edison Company Purchasing and Engineering

SS and Construction groups; and for plant operations quality assurance programs covering plant maintenance, repairs, operations, in-service inspections and modifications.

For operating stations, the Corporate Quality Assurance Program activities also are covered by written policies, programs, procedures and instructions included in the Station Procedures Manual and other documents. The Manager of Quality Assurance / Nuclear Safety responsibilities include the establishment and control of the Station Program, preparation and_ authorization of the Quality Assurance Procedures for operations,

55 and audit and verification of station activities as to the adequacy of the Station Program's implementation.

The Station Manager provides written procedures and instructions for the Station Procedures Manual and administers the policies, procedures and instructions from the time the Operating License is issued

5S throughout the operating life of the station.

The Quality Assurance Program takes into account the need for special controls to maintain the required quality and the need for verification of quality by inspection and test. The Station activities affecting quality are accomplished in accordance with the Corporate Quality Assurance Program using appropriate equipment and suitable conditions, and completing prerequisites. Disputes of a major nature between the Quality Assurance Department and organizations which cannot be resolved will be referred to higher management for resolution. 2-3 Rev. 55 3/27/89 Commonwealth Edison

Achievements of the applicable requirements of the Codes, standards and specifications for materials, structures e.quipment and i l-systems will be verified through independent quality control activities. The control activities will encompass design, procurement specifications, materials, processes, procedures, identifications, testing, nonconformance, corrective action, documentation, handling, storage, operating, maintenance, modifications, in-service inspections and repair. Commonwealth Edison Company personnel involved in Company Quality Assurance activities will be primarily involved in audit and surveillance of quality control and assurance activities performed by various contractors and other Edison personnel. Inspection, testing and examination activities generally will be performed by outside independent testing service contractors. To achieve the necessary background and experience for Commonwealth Edison personnel in quality control and assurance activities, indoctrination and training programs will be established by the Manager of Quality Assurance / Nuclear Safety or his delegated

55 representative to assure such personnel will have adequate knowledge or skill to perform these activities.

These indoctrination and training programs will be an extension of their formal education or work experience. The training program to qualify and/or certify people for the

55 quality assurance work activities they perform will consist of, but not be limited to, the following methods as required:

1. Company Quality Assurance Program Orientation 2. Formal Training Programs - classroom and hands-on 3. On-the-job Training - inspections, auditing, testing, etc. 4. Industry Seminars - concrete, coatings, QA/QC, etc. 5. Inter-and Intra-Departmental Sessions The orientation sessions covering the Quality Assurance Program will include engineering, construction, production, Quality Assurance, purchasing, licensing, System Materials Analysis and System Operational

ss Analysis personne!. Various personnel at all levels of site and station activities and general functions will be included.

These orientation sessions are intended to acquaint personnel with quality assurance / quality control functions and inter-and intra-departmental responsibilities, and to serve as a feedback mechanism to assess and

55 evaluate the Commonwealth Edison Quality Assurance Program.

2-4 Rev. 55 3/27/89 Commonwealth Edison

l Individuals engaged in the quality assurance program (Engineering, Construction, Production, Quality Assurance, Purchasing, System Materials Analysis and System Operational Analysis) activities

55 will be involved in formal training programs utilizing outside agencies and consultants and, as required, will include the following subjects:

1. Quality Assurance / Quality Control princ'fples 2. Codes and Standards' 3. Nondestructive Examination (principles and practices) 4. Special Processes '5. Audits The "On-The-Job" Training program will involve new personnel working under the tutelage and direction of experienced and qualified quality assurance personnel. Ir1 addition, these programs will include the following as required: 1. Site and Off-Site Seminare for selected subjects 2. Group discussions and prt tem reviews 3. Individual training and tutoring 4. Appropriate company and other educational courses The utilization of Industry Seminars will be made as appropriate for responsibilities and disciplines involved. Edison personnel engaged in testing activities will be assigned according to their formal education and on-the-job experience. Additionally, training programs will be developed to indoctrinate and qualify personnel in specific inspection, testing or examination activities in which they will be engaged. The System Materials Analysis

55 Manager will be responsible for the development and execution of these programs.

Training will be conducted in a time frame adequate to prepare personnel for their job responsibilities. When a project or station organization is developed, the Nuclear Quality Programs Manager and

55 Quality Assurance Superintendents are responsible for reviewing the adequacy of trained and certified personnel and recommending necessary training progr_ams.

Retraining sessions will be scheduled to assure that adequate skills are maintained for qualified and/or certified personnel. Certification records will be maintained by the Quality Assurance Department as well as the department where in the employe performs his activities. Qualification and certifications will be maintained in a current status and will be established to meet the applicable requirements of ASME Code including ANSI /ASME NQA-1 and as provided and committed herein. l 2-5 1 Rev. 55 3/27/89 ) Commonwealth Edison u___ - _--

The training and certification of personnel associated with nondestructive examination will be carried out in accordance with the requirements of SNT-TC-1A and the Code. A Level III certified person will administer this activity and the program will be under the surveillance of the Nuclear Quality Programs Manager and the

ss Superintendent Quality Assurance Central Committee or their delegated representatives.

Likewise, a Level III certified person will administer the concrete containment inspection as applicable under Division 2 of the ASME Code. Training and certification of personnel associated with concrete containment inspection will be carried out in accordance with Appendix VII of ASME Section III, Division 2. The period of qualification shall be a minimum of two and a maximum of three years. Near the end of such a period, employes will be notified that they will require either retraining and requalification and/or decertification to renew their qualification status. Contractor personnel engaged in inspection, examination and testing activities will be required to be trained, qualified and certified to perform their specific activity in accordance with the above requirements. Such training shall be dccumented and the record of those receiving training shall include as a minimum the date, duration, subject, the name of the person who performed the training, and the name of the person being trained. The objectives of the Commonwealth Edison Company Quality Assurance Program are to: (1) establish with confidence that the design, fabrication, erection and operation phases of its nuclear power generation facilities are performed in a manner consistent with the policies stated above; (2) provide for documenting, retaining documentation and updating design, fabrication, erection and product quality information necessary for Commonwealth Edison Company operation, maintenance, repair, modification, refueling and in-service inspection of the nuclear power facilities: (3) avoid schedule delays and high cost due to poor quality; and (4) achieve high plant reliability and availability. The Quality Assurance Program applies to safety related and ASME Section III activities, items and related consumables, plus fire protection, security, emergency plan, meteorology, radioactive i material transport packages, and review of environmental qualification of Class IE Equipment and requirements of the Jurisdiction. The classification of structures, systems and components designated as " safety related" are listed in the respective Safety Analysis Reports (SAR) of the Stations. A copy of the SAR or the listing will be available in the Operations, 2-6 Rev. 55 3/27/89 x Commonwealth Edison 1

l l Construction, Quality Assurance and Engineering areas, as necessary, for reference. Distribution of and revisions to this listing are

ss controlled and approved by the Nuclear Engineering Department.

The requirements in ASME Section III, Article NCA-4000 shall be applied to Section III systems and components including concrete containments. The 18 Criteria of Appendix B of 10CFR50 will be applied to safety-related systems and components for design,, construction, maintenance, refueling, in-service inspection, repair and station modifications. Criteria 1, 2, 5, 6, 10, 11, 12 and 14 to 18 and Regulatory Guide 1.33 will be applied to operation of safety-related systems and components. The Manager of Quality Assurance / Nuclear Safety will be +55 responsible for assuring a regular review of adequacy of the Quality Assurance Program. Periodic written reports will be provided to upper management covering activi. ties and problems involving the requirements of the Quality Assurance Program. Also, an overall report will be made annually to upper management for their assessment as to scope, status implementation and effectiveness of the Quality Assurance Program to assure that it is adequate and complies with 10CFR50, Appendix B Criterta. An independent management audit for upper management shall be conducted on a two year cycle to evaluate the status and adequacy of the Quality Assurance Program. This annual assessment is preplanned and documented. Required corrective action is identified and tracked. The Quality Assurance Programs in the Commonwealth Edison Company Quality Assurance Program Manual and revision thereto are l approved and controlled by the Hanager of Quality Assurance / Nuclear

ss Safety and may only be revised with his approval.

The Quality Requirements and Quality Procedures shall be revised in concert with addenda to reflect revisions in Section III of the ASME Code. Such revisions to the Quality Requirements involving ASME Section III shall require acceptance by the Authorized Nuclear Inspection Agency and notification plus evidence of such acceptance to the Authorized Nuclear Inspector prior to issuance. Concurrently, a copy of the i updated Corporate Quality Assurance Manual shall be made available l to the Authorized Nuclear Inspector at stations where Code work is being done. Programmatic changes to the Program are submitted to the NRC Regiortfor acceptance prior to implementation, 1 Organizational changes are submitted within thirty days of the j effective date. Changes which do not reduce commitments must be l submitted to NRC at least annually for changes affecting operational l stations, and within 90 days of implementation for changes affecting I stations under construction. Changes which reduce commitments must be submitted to and approved by NRC before being implemented. These requirements also extend to the " principal contractors"--the Architect-Engineer and the Nuclear Steam Supply System vendor for each project. Initial assurance that the current Q.A. program description for each of these contractors has NRC approval, either as a part of the Safety Analysis Report or as a separate Quality Assurance Topical Report applicable to the respective projects, will be established by audits. These Edison 2-7 Rev. 55 3/27/89 Commonwealth Edison

audits will also assure that each principal contractor has audited its Subcontractors, so that changes in those firms' respective programs have not abrogated commitments in the principal contractors' programs and that such programs continue to meet 10 CFR 50 Appendix B requirements. Quality Assurance Procedures involving engineering, construction, operating, maintenance, modification, in-service inspection and Stores activities, and revisions thereto, are signed by the Head of the principally involved department (s) and

ss approved by the Manager of Quality Assurance / Nuclear Safety.

Approval of the Quality Assurance Program Manual Indexes indicates approval of respective changes to the individual pages of the Corporate Quality Assurance Manual. Sections 2, 5 and 18 of the Quality Procedures' provide the procedures for implementing this section of the Quality Requirements. l . -a. i 2-8 Rev. 55 3/27/89 l Commonwealth Edison ) i

3. DESIGN CONTROL 3.1 General The fundamental vehicle for design control involves multi-level review and/or evaluation of design documents by individuals or groups other than the original designer or designer's immediate supervisor whose authority and responsibility are identified and controlled by written procedures. Also, procedures are established to assure that verified computer codes are certified for use and that their use is specified. The design documents include, but are not limited to, system flow diagrams, design and construction specifications, load capacity data sheets, design reports, equipment specifications, process drawings. Design calculations are also subject to two or more levels of evaluation or review including that performed by the originator plus review and audit by the Nuclear Engineering Department for modifications where

55 design work is performed by the Architect Engineer or other vendors or contractors. Design changes are controlled through document revisions resulting from design change requests and/or design change notices and are reviewed, evaluated and, where appitcable, certified in the same way as the basic design documents.

These design evaluations or reviews are conducted to written procedures and include consideration of quality standards, quality assurance requirements, materials suitability, process suitability, interface control and suitability of analytical or testing requirements as appropriate. Also, design verification, except for ASME Code items, may be achieved under a test program by qualification testing of an item under adverse design conditions. Responsibility for overall design and design control of mechanical, electrical, structural and nuclear related systems and components and compliance of responsibilities to Section III of the ASME Code is assigned to Projects Engineering, where established,

55 during the initial design and construction and to the Nuclear Engineering Department after plant start-up. Quality Assurance shall assure that design control requirements are fulfilled through review and audit.

j The extent of the design review and evaluation of the original designs and modifications will be determined by the complexity of the system and any safety-related function to be s performed by that system. Design evaluation of modifications will

55 j

be commensurate with those applied to the original design. Review and evaluation by the Architect Engineer, the Nuclear Steam Supply System vendor, Projects Engineering and/or the Nuclear Engineering Department, as appropriate, and other CECO. organizations, and

55 specially qualified people, such as level III's for NDE and for concrete inspection and tests, will assure that designs, specifications and procedures will conform to the ASME and other applicable codes, standards, regulatory requirements, SAR commitments and appropriate quality standards, as applicable.

3-1 Rev. 55 l 3/27/89 Commonwealth Edison \\

Projects Engineering, where established, during initial

55 design, and the Nuclear Engineering Department, after p1' ant start-up, will review and evaluate the overall design for safety, reliability, inspectability, maintainability and constructability.

The Vice Presidents (BNR and PHR Operations) are responsible for review of +55 designs for operability, inspectability and maintainability. The Nuclear Fuel Services Department.will be responsible for either performing reactor core design analyses or for reviewing vendor generated analyses. The Nuclear Fuel Services Department is also responsible for the design specifications and design reviews for nuclear fuel and in-core components, including when actual work is delegated to other areas. Coordination of the design review and evaluation effort by Projects Engineering and the Nuclear Engineering Department, as

55 applicable, will be, in part, directed toward the identification and control of design interfaces, radiation and environmental requirements, functions and boundaries, and selection and application of materials, parts, equipment appurtenances and components.

Design analysis shall be performed in a planned, controlled and documented manner. Documentation of the design analysis shall include. definition of the objective of the analysis, definition of design inputs and their sources, results of literature searches or other applicable background data, identification of assumptions and indication of those that must be verified as the design proceeds, identification of any computer calculations, including, code or program validation review and approval. Projects Engineering or the Nuclear Engineering Department, as

55 applicable, with assistance from other organizations, contractors or vendors, shall apply, as applicable, design review and control measures to items such as:

reactor physics; loads and loading combination, transtent and accident analysis, compatibility of materials, structural support, accessibility for in-service inspection, maintenance and repair; and delineation of acceptance criteria for inspections and tests. Projects Engineering or the Nuclear Engineering Department, as

55 applicable, the Architect Engineer or Nuclear Steam Supply System Supplier interpret appilcable requirements, standards, guides or codes (including classification of ASME Socion Section III items) and use them as a basis for classifying structures, systems -and components and establishing. boundaries of jurisdiction in each nuclear power plant.

Evidence of design evaluation and reviews and use of alternative calculational methods used to assure verification or checking of design adequacy will be documented and retained by Projects

SS Engineering and by the Nuclear Engineering Department, as applicable, or by the Nuclear Fuel Services Department for fuel or in-core related matters.

Errors and deficiencies discovered shall be documented and 3-2 Rev. 55 3/27/89 Commonwealth Edison i

l appropriate corrective action shall be taken. The Projects Engineering $55 / i Manager, there established, prior to plant start-up, and the Nuclear Engineering Manager, after plant start-up for plant modifications, or by the Nuclear Fuel Services Manager for fuel or in-core related matters for plant operations, or their respective agent or designee shall certify that a review of the Design Report / Load Capacity Data Sheets has been conducted to a>ssure that all the Design Specification and applicable Code requirements have been considered. Copies of the certification shall be attached to the copies of the Design Report, design drawings, stress calculations and Design and Construction Specifications and Reports which are made availa.ble, as applicable, to the Authorized Nuclear Inspector for review and c' certification and the enforcement authorities having jurisdiction over the nuclear power plant installation as provided by ASME Section III of the Code for Classes 1, 2, 3, CS, MC and CC. Design information transmitted across interfaces shall be documented, controlled, and include the status of the information or document. 3.2 Desian Chances Changes to drawings used for construction from the corresponding drawing used for stress analysis shall be certified, by the person or organization responsible for the stress analysis calculations, to have been satisfactorily reconciled with those calculations. Design changes are controlled through document revisions resulting from design change requests and/or design change notices and are reviewed and evaluated in the same way as the basic design documents. Site and Station design change requests will be reviewed by the Site Quality Assurance Superintendent, or designee, Station Quality Assurance Superintendent, or designee, Technical Staff Supervisor, Projects Engineering personnel or Nuclear Engineering personnel after

55 plant start-up for plant modifications, and/or Architect Engineer, as applicable, and will be approved by Projects Engineering or the Nuclear
55 Engineering Department after plant start-up for plant modifications after which the approved change will be incorporated in design documents, approved, released and distributed.

The extent of the evaluation will be determined by the complexity of the change and its safety-related function with respect to the original design. Coordination of review and evaluation of design changes will be by Projects Engineering or the Nuclear Engineering

55 Department after plant startup for plant modifications.

The control of documents will be maintained within the system described in Quality Requirement 6.0, " Document Control." Plant modifications will be evaluated in accordance with the requirements of 10CFR50.59 and to the requirements of the ASME Boiler and Pressure Vessel Code Section III and will be submitted to the Manager of Quality Assurance / Nuclear Safety, Superintendent of Off-Site I

ss l

Review and the Production Superintendent. Also, for Code work the modification will be reviewed with the Authorized Nuclear Inspector who will then stipulate the inspections he intends to make prior to l implementation of the modification work. The Production Superintendent I authorizes the modification. The Technical Staff Supervisor reviews and 3-3 Rev. 55 3/27/89 Commonwealth Edison )

l l' 1 approves the proposed modification and is responsible for verifying that operating procedure changes are accomplished as to station modifications. The station Training Supervisor is responsible that i required training concerning plant modifications is accomplished for responsible plant personnel where the performance of their duties may be affected. Quality Assurance assures such training is completed. The Nuclear Licensing Manager reviews and the

55 Superintendent of Off-Site Review reviews and approves proposed modifications to plant systems and components inv'olving a revision to the Technical Specifications or a previously unreviewed safety question.

Evaluation and approval of the substitution of equipment is performed by the Technical Staff Supervisor and either the Production Superintendent, Assistant Superintendent of Operating or +55 Assistant Superintendent of Maintenance. Projects Engineering, Nuclear Engineering or equipment vendors provide engineering analysis as required by the design specification. Projects Management or Nuclear Engineering shall assign an

ss organization to verify installation of modifications in accordance with design and quality assurance requirements.

When modifications cannot be completed in accordance with drawings and specifications, a review for disposition will be requested of the cognizant Engineering Department. The verifying or checking of design features and modifications is done by qualified individuals or organization other than those who prepare the original design or design modification but who may be from the same organization. The assigned installation department furnishes Projects Engineering and, after plant start-up for modifications, the Nuclear

55 Engineering Department, as-built information to review as to correctness and to issue as-built drawings.

Test data required by Projects Engineering involving

55 initial construction and by the Nuclear Engineering Department involving modification to verify the satisfactory installation of components is obtained by organizations designated by them.

After completion of construction, station operating personnel and station Quality Control personnel verify the

5S satisfactory final testing of. systems required by Projects l

Engineering or Nuclear Engineering. Also, where applicable, before

55

{ the component or appurtenance is placed in service, copies of the j appropriate ASME Data Reports and Certified Design and Construction Reports and Design and Construction Specifications are filed at the location of the installation and made available to the Authorized Nuclear Inspector and the State of Illinois enforcement authorities having jurisdiction. Completed Data Report Form N-3, however, shall be filed by CECO with such enforcement authority having jurisdiction. 3-4 Rev. 55 3/27/89 Commonwealth Edison

l

4. PROCUREMENT DOCUMENT CONTROL The procurement documents include equipment specifications or specifications for services, each of which are reviewed or eval-uated as described in Section 3 for design and construction, and design and construction for modifications.

Changes to procurement documents are subject to the same review and approval requirements as the original documents. Contract or purchase order. documents are reviewed by the NSSS Supplier for NSSS items and by Edison and the. Architect Engineer for non-NSSS items to insure that all require-ments have been incorporated specifically or by reference. Records pertaining to the review and evaluation of procure-ment documents involving initial plant installations and plant modi-fications will include, in whole or in part, minutes of meetings, comment letters, design review records, project quality assurance audits and a copy of the original design document marked with comments or latest revisions..These records will be kept in vendor flies and/or applicable Commonwealth Edison Company department flies during the Engineering, Construction and Operation phases of the generating station. The quality assurance and engineering requirements including documentation requirements, will be stated, as applicable, in the bid package, contracts and purchase orders for safety-related and ASME Code related procurement. Also, the review for suitability of application of commercial grade or previously .ss approved materials, parts and equipment that are safety-related will be imposed on vendors. Where material, equipment, systems or services require contractors to adhere to ASME Code requirements or have ASME Certificates of Authorization, these requirements will be contained in the procurement documents. Quality Assurance Program requirements, as well as requirements for subtier procurement, are included as regulatory, code, standard and design requirements. Similarly,.the required methods of identification, preservation and packaging, and methods.of controlling conformance to acceptance criteria are covered by these documents. Quality Assurance Program requirements are included in initial procurement contract and reviewed for acceptability by Quality Assurance to provide for impleinentation of the approved quality assurance program, vendor evaluation, inspection and test planning, vendor surveillance, witnessing of inspection control points and inspection documentation. Also, requirements for vendor documents, such as 4-1 Rev. 55 3/27/89 Commonwealth Edison L____-___

instruction, procedures, drawings, specifications and vendor quality assurance records to be prepared, submitted or made available for review or approval are included. In addition, included in the procurement documents are provisions for right-of-access to vendors' facilities and work documents for inspection and audit and for vendor i reporting and disposition of nonconformance from procurement requirements. Procurement control is by CECO with procurement of major

55 equipment and items being purchased by the General Office Purchasing Department and procurement of standard type materials and items being performed by its satellite purchasing organization, where established
55 at certain sites.

For procurement initiated by Projects Engineering or

55 Nuclear Engineering, the cognizant Project Manager or Design Superintendent / Supervisor, or designee, as applicable, prior to submittal of the Engineering Proposal Request to the Director of Procurement, prepares a suggested list of prospective bidders for each specification from the applicable Approved Bidders' List using input from the Architect Engineer and the cognizant Purchasing Department Buyer.

The Bidders lists are established using such factors as past experience, experience of other utilities, or specific qualification surveys. For Code work, the desk survey shall

ss be limited to determination that a supplier or contractor is the holder of a valid Certificate of Authorization for the scope of work involved or for determining if a supplier or contractor is potentially qualified.

The final list of prospective bidders, as well as the person agreeing to the list as indicated on the Nuclear

55 Proposal Request (NUPR), is approved by the cognizant Project Manager or the Nuclear Engineering Manager for modifications or designated alternates.

The persons agreeing to the list are key representatives of Projects Engineering and Projects Construction, or the Nuclear

55 Engineering Manager and the Engineering and Construction Department after plant start-up for modifications, BWR/PHR Nuclear Operations, j

the Purchasing Department and, when requested, the Architect Engineer. Where bids are obtained from prospective bidders other than those listed on the Quality Approved Bidders' List maintained by i the Quality Assurance / Nuclear Safety Policy and Oversight Department

55 for the Purchasing Department, such bids shall be indicated as trial bids and shall be treated as trial bids until the bidders are evaluated and approved as acceptable prior to award.

Upon completion of the evaluation of the proposals from approved bidders for either original plant or plant modification items or services, the responsible Project Manager or Design Superintendent / Supervisor shall have prepared and, after final review and approval indication by the Quality Assurance Coordinator, shall have transmitted to the Purchasing Department a letter of recommendation and a purchase requisition. The purchase requisition and/or letter will 4-2 Rev. 55 3/27/89 l Commonwealth Edison

U. incorporate, by reference, those documents such as specifications, drawings, proposals, etc., and any conditions of award which form

55 the basis for the evaluation and award.

Purchasing, based on the recommendation letter, its own evaluation and the purchase requisition, shall conduct necessary negotiations and clarifications and make the award to the successful bidder. Any changes evolving from the procurement activities involving technical or quality assurance matters, either for the original purchase or subsequent change orders, shall be approved by the originator of the purchase or change order requisition. The Projects Engineering Manager, or the Nuclear (55 Engineering Manager, after plant start-up, will assign authority for evaluation of the vendor quality assurance program, prior to final award of the contract or purchase order, to the Director of Technical Services who will be assisted in such evaluation by the Superintendent of Off-Site Audits. Quality Assurance / Nuclear Safety

55 Policy and Oversight Department shall evaluate and approve all such vendor quality assurance programs.

The Quality Assurance Coordinator assigned to the Projects Engineering and the Nuclear

55 Engineering Departments is responsible for assuring that the evaluation is carried out and for auditing the manuals of bidders being recommended as acceptable for award as to resolution of comments received by Engineering. As part of the vendor quality
55 assurance program evaluation, the Quality Assurance Coordinator will assure all vendor quality assurance program deficiencies are resolved.

Concurrence by Quality Assurance / Nuclear Safety shall be

SS required.

If the vendor program deficiencies are minor and/or may be corrected by specific procedures for the work to be done, the resolution may follow an award and shall be a condition of the award. For procurement performed at certain construction sites by the Purchasing Department satellite organization involving safety-and Code-related items, the preparation of the necessary procurement documents is the responsibility of Projects Construction. Procurement by the site Purchasing organization are under the control and management of the General Office Purchasing Department and associated procurement documentation packages are formulated from specifications and drawings issued and approved by Engineering. The cognizant Field Engineer or, as appilcable, the Projects Field Engineering Manager, prepares the suggested list of prospective bidders for each procurement package from the Quality Approved Bidders' List with direction from the site Purchasing Department Buyers. The final list of prospective bidders and procurement bid package is approved by the site Projects

SS Construction Superintendent or Projects Engineer or their designated alternate.

In addition, such procurement bid packages involving the purchase of ASME Code and safety-related materials and items are +55 4-3 Rev. 55 3/27/89 Commonwealth Edison

i required to be reviewed and approved by the Site-Quality Assurance Superintendent, or designated alternate, verifying that the necessary technical and Quality Assurance requirements are included I and the proposed bidders are acceptable. The bids are evaluated by Projects Construction and an

ss award recommendation plus a purchase requisition,is prepared and transmitted to Purchasing via the Site Quality Assurance Superintendent, or designated alternate, for final review and concurrence indication.

Site Purchasing, based on the

ss recommendation of Projects Construction, its own evaluation and the purchase requisition, conducts necessary negotiations and clarifications and make.the award to a bidder on the Quality Approved Bidders' List.

Any changes evolving from the procurement activities involving technical or quality assurance matters, either for the original purchase or subsequent change orders, shall be approved by the originator of the purchase or change order requisitions as well as Quality Assurance. The Manager of Fuel is responsible for the preparation of

55 nuclear fuel bid documents, for the evaluation of bids received and i

for the purchase of nuclear fuel. The Nuclear Fuel Fabrication Inspector provides quality assurance assistance. The Nuclear Fuel Services Manager, and others as necessary, furnish technical assistance to the Nuclear Fuel Agent during the preparation of bid documents and the evaluation of bids. When the Assistant Superintendent of Maintenance or

55 Technical Staff Supervisor orders spare parts, material and equipment for safety-related items, components and modules to applicable-engineering and quality assurance requirements, they specify the quality assurance documentation requirements equivalent to or better than the original installation. Mhen spare parts, material and equipment are ordered by part number or nomenclature without special engineering requirements being specified, appropriate statements are included in the purchase order to assure they are at 4

least equivalent to the original equipment. The Quality Control ) Supervisor shall review and verify that quality assurance, specification, ASME Code and other applicable codes and standards requirements.and special requirements are included in the Request ) for Purchase. ) i The procurement documents are reviewed and processed by the Support Services staff in the Stores and Inventory Control

55 Department.

Coded part numbers are assigned to spare parts. The ] Support Services staff and the Manager of Quality Assurance / Nuclear I Safety, or designee, review and approve that the quality 1 requirements for documentation of spare parts, welding materials, material and equipment as outlined above, are included in the procurement request documents and that the items are ordered from the original equipment supplier or an evaluated and approved alternate supplier. 4-4 Rev. 55 3/27/89 Commonwealth Edison

l The bid package and the resulting contracts or purchase order will clearly reference applicable revision dates of appro-priate drawings and specifications for the item or service being procured. Appropriate revisions of ANSI, ASME or other applicable codes and/or standards will be considered a part of the design requirements and be referenced in the bid package, contract or purchase order. The bid package and resulting contr'act or purchase order will contain the requirements for inspection, testing and inspection documentation. Commonwealth Edison Company, its contractors, subcontractors and vendors will be responsible for their respective programs by which an appropriate review and audit will determine that the requirements of this Section have been met. Procurement documents will identify which records indica-tive of quality will be transmitted to Commonwealth Edison and the method of dispositioning those which the vendor retains. The bid package and resulting contract or purchase order will contain, as applicable, the requirement for the contractor to have and implement a quality assurance program which has been approved by CECO for purchased safety-related and ASME Code materials, equipment and services to an extent consistent with their importance to safety and will state the controls which will exist between the purchaser and seller in requesting and accepting changes under the purchase order or contract. Also, revisions to such quality assurance programs shall be submitted to CECO for review and accep-tance during the term of the contract or order. Procurement of spare parts or replacement items will be subject to controls at least equivalent to those used for the original equipment. l 4-5 Rev. 16 3/16/81

l l

5. INSTRUCTIONS, PROCEDURES AND'DRAHINGS I

The quality assurance actions carried out for design, l construction, testing, and operation activities will be described in I documented instructions, procedures, drawings, specifications, or checklists. These documents will assist personnel in assuring that ) important activities have been performed. These documents will also reference applicable acceptance criteria which must be satisfied to assure that the quality related activity has been properly carried out. Activities affecting quality are required by the Edison quality program to be prescribed by documented instructions, procedures or drawings. Procurement documents and the corporate guality assurance programs of Edison, the NSSS Supplier and Architect Engineer reflect this requirement. Each Edison Department involved in safety-related and ASME Section III Code work shall have documented procedures to implement their responsibilities. Quality Procedures as part of the Commonwealth Edison Company Quality Assurance Manual will be written for design, construction, testing, operations, maintenance and repair activities. Where appropriate, these procedures will include checklists containing the necessary elements of operation to be observed or measured. These checklists will be used to the maximum extent practical to document the actions performed. Generating Station operations, procedures and instructions will be provided by the Station Manager and will be included in the Station Procedures Manual in a timely manner consistent with NRC license requirements for administering the policies, procedures and instructions from the time that the Operating License is issued through the life of the station. These procedures and instructions include: Administrative Procedures, Overall Station Procedures, System Operating Instructions, Chemical Control Procedures, Emergency Operating Procedures, Surveillance Procedures, Maintenance Procedures, Instrumentation Procedures, Radiation

ss l

Control Standards and Nuclear Operations Directives. Also, a Station Quality Assurance Program for Maintenance, Modification, In-Service l Inspection and Stores Activities will be provided. The procedures i 5-1 Rev.55 3/27/89 Commonwealth Edison i

I include specifications and acceptance criteria as well as vendor documents. Complex procedures include checklists as part of the procedure and caution notes applicable to specific steps in the procedure i are included. The current revision of the Station Procedures Manual is available in the Station Control Room and is additionally provided to key operating and management personnel. { Maintenance and repairs to structures and equipment after construction and testing is completed are the responsibility of each i Assistant Superintendent of Maintenance and are performed in accordance

ss with applicable drawings, procedures, instructions, and/or checklists for Code and safety-related. work. When ASME Code work is involved, these documents.shall be submitted to the Authorized' Nuclear Inspector for insertion of his hold points.

Drawings procedures, instructions and/or checklists are used for maintenance and repairs outside the scope of normal station craft maintenance capability. When procedures and/or checklists are not available for work outside the scope of normal station maintenance craft capability, an outline of the steps to be followed will be prepared to assure proper completion and testing of the maintenance or repair work. These procedures and/or checklists or outlines are supplemented as necessary by instructions from the personnel responsible for directing the. specific maintenance or repair work. Maintenance, modification and: inspection procedures and other quality assurance related documents are reviewed by Quality Assurance personnel to assure the need for inspection, identification of inspection personnel, and documentation of inspection results plus necessary inspection requirements, methods and acceptance criteria is provided. Each Station Manager or his designee is also responsible for +55 preparation of procedures to assure the safe operation and refueling of the Station in accordance with requirements of the NRC operating license. The Vice Presidents (BWR and PHR Operations) provide direction

55 for the preparation of necessary instructions and procedures to accomplish the station activities in a uniform and systematic manner.

Procedures and instruction supplementing the Quality Procedures of the Quality Assurance Manual will be prepared, as required, reviewed and approved within the individual departments, generating stations and construction-ntes responsible for the activities involved as the need arises and their use monitored by Quality Assurance administration. Any CECO departmental group involved with nuclear plant design, procurement, construction or operation may propose procedures as necessary to meet regulatory, ASME Code or other applicable code requirements. 5-2 Rev. 55 3/27/89 Commonwealth Edison

_ - - _ _ _ _ =. i 2: l .1 1 The procedures will be independently reviewed and evaluated by other involved departments with interface responsibilities and the comments i forwarded to the issuing department. l l 5-3 Rev. 36 6/19/85 Commonwealth Edison

I 1 1

6. DOCUMENT CONTROL A document control system will be used to assure that documents such as specifications, procedures, instructions, and.

32 drawings.are reviewed for adequacy and approved for release by.

authorized personnel. ;Also, this system includes as-built drawings .and provisions to assure as-built drawings are kept updated, properly maintained, and controlled. Such documents will be distributed to and used at the locations where the prescribed activity is performed. Changes to:these documents will be handled similarly and will be reviewed and approved by the same organization that performed the original review and approval, unless delegated by the originating organization to another responsible organization. Documentation will identify design documents, provide a schedule for completion, define design milestones or other control points, and identify design responsibilities with particluar attention to the definition of organizational interfaces. Design documents will include ASME Code, seismic and other analysis reports, drawings, equipment specifications, work instructions, test

procedures, etc., necessary to achieve proper procurement, installation, start-up and operation of systems and components in accordance with engineering requirements. Document control will include documents containing requirements for materials, fabrication, special processes, testing, inspection, cleaning, packaging, shipping, storage, maintenance, refueling, operations, and plant modifications, as applicable.

The fundamental control vehicles for documentation relating to Safety Category I systems, structures-and components are project distribution lists and periodic document status reports. The Architect Engineer acts as the general distribution agency for . project-documents (except for internal Edison Quality Assurance Procedures) and carries out the distribution in accordance with a list furnished by Edison for specific types of documents. Both the Architect Engineer and the NSSS Supplier publish periodic 6-1 Rev. 32 10-05-84 Commonwealth Edison

i. l { status reports identifying those documents currently in force. l These reports are distributed to all involved parties. Each document recipient is responsible for insuring that only the latest authorized documents are in use and that void documents are i so identified. Periodic inspections and audits by Quality Assurance are employed as a final check to assure that the latest authorized documents are in use. Master distribution lists will be used and will designate recipients of document copies. This listing shall include document changes, distributions for comments, and/or distribution for use. Quality Assurance Manual distribution and revisions, thereto, are controlled by Quality Assurance using a master distribution list. Design document distribution lists applicable to each project shall be developed by the Projects Engineering Manager or

SS the Nuclear Engineering Manager, as applicable, and will be coordinated with other CECO personnel as deemed appropriate by the cognizant Project Manager or Design Superintendent / Supervisor, as
55 appilcable.

Each list will include an issue date, revision date, and number, project identification, types of design documents, listing of various document recipient positions and the number of copies of each position. Each list will be distributed to the Architect Engineer and to all recipients identified on the list and will be accessible to the Authorized Nuclear Inspector for +55 review and use. The distribution of documents will be made by the Architect Engineer, or respective Project Manager or Design

SS Superintendent / Supervisor, as applicable, in accordance with the distribution list for each project.

Each recipient listed on the distribution list shall, upon receipt of new documents, destroy or segregate and clearly mark all superseded documents. Each receiving office or area shall have a controlled method for checking receipt of new or revised documents, and assuring that the latest revised document is in use. Status reports will be issued periodically by Projects Engineering or Nuclear Engineering, as applicable, Architect

55 Engineer and NSSS Supplier to all parties on the distribution list stating the latest revision of documents to assist recipients in maintaining up-to-date files.

Each document recipient on the distribution list is responsible for insuring that only the latest authorized documents are in use and that void documents are so identified. The responsible Projects Department Project Manager or

ss the Nuclear Engineering Department Design Superintendent / Supervisor shall periodically have the document status reports reviewed to confirm that the latest revised documents are in use.

Also, verification of compliance to this procedure by a physical check of document files, will be periodically performed by CECO Quality Assurance. f i 6-2 l Rev. 55 l 3/27/89 ) Commonwealth Edison

l The cognizant Projects Department Project Manager has the +55 responsibility to establish document control procedures and methods during design, construction, preoperational and start-up testing. The Nuclear Engineering Department Design 55 Superintendent / Supervisor for plant modifications, as i applicable, has the responsibility to assure that documents are reviewed for adequacy and are approved by authorized personnel for issuance and use at locations where the presYribed activity will be performed before the activity is started. The Station Manager has the responsibility to establish document control procedures for operation, refueling, maintenance, and repair. Distribution and revisions of documents at the station are controlled by Central File in accordance with Station Administrative procedures. The station Office Supervisor maintains the station files for controlled documents. Superseded documents retained for reference are so marked. The Assistant Superintendent of Maintenance assures the

55 latest revisions of documents for maintenance and repair are in their working files. The Technical Staff Supervisor will incorporate changes to maintenance and operating criteria into station procedures and instructions in a timely manner.

The Engineering and Construction Department or the

$5 responsible Maintenance Department, whichever has prime responsibility for new plant construction or modification work, shall be responsible for collecting and retaining the inspection and test documentation during construction and installation of assigned plant modifications and for transferring such documentation to, or within, the station for review and acceptance and permanent filing.

6-3 Rev. 55 3/27/89 Commonwealth Edison

l l 7. CONTROL OF PURCHASED MATERIAL, EQUIPMENT AND SERVICES 7.1 General The control of the quality of purchased material, equipment and services is achieved through the evaluation of vendors, surveli lance of their operations and required source inspection, documentu tion, receiving inspection and retention of quality records. Both Edison and the NSSS Supplier have direct procurement functions for the Station. The Architect Engineer offers recommendations to Edison on vendor selection and reviews vendor efforts as directed by Edison. Edison will inspect and audit the NSSS Supplier's control of purchased material, equipment and services. Edison has the responsibility for on-site control of Edison and the NSSS Supplier i purchased material, equipment and services. 1 Contractors and suppliers furnishing material, equipment and services to CECO for items within the jurisdiction of this Quality Assurance Program will be selected on the basis of demonstrated capht.ility to provide a product, process or service in accordance with Me design specifications and contract provisions. The purpose of this Section is to define the quality system elements and related policies which assure the quality of purchased i material, equipment and services through the evaluation of vendors, surveillance of their operations, required source inspection, documentation, receiving inspection and vetention of quality records. I 1 As applicable, the cognizant Projects Department Project

55 Manager or the Nuclear Engineering Department Design Superintendent / Supervisor in conjunction with Quality Assurance will require a Quality Assurance Program in accordance with ANSI /ASME NQA-1 and the daughter standards of ANSI N45.2 not included in ANSI /ASME NQA-1 or ASME Boiler and Pressure Code Section III from vendors or contractors, consistent with the importance of the procurement to station safety and operation and the requirements of ASME Section III and 10CFR50, Appendix B.

For ASME Code and safety-related procurement, the applicable vendor's Quality Assurance program shall be identified in the procwer 9t documents and shall require certification to their QA Progiun a cepted by CECO

ss and shall identify the QA Program revision and date to which the work was performed or item supplied.

In addition, Edison's procurement documents will provide notification to vendors and contractors that the provisions of 10CFR Part 21 apply. l l l 7-1 i Rev. 55 3/27/89 Commonwealth Edison 1

Control and approval of subcontractors' quality assurance programs, procWres and personnel qualifications, are the +55 responsibility - the specific contractor involved. Such contractor actions are to be documented and will be subject to audit by Commonwealth Edison Company.

55 An evaluation of vendor capability will be required for ASME Section III and safety-related items. Where val,id records of vendor capability and quality performance are not availa'ble to CECO, a survey of the supplier's facilities, capabilities and quality assurance system will be made by CECO or its designated representative.

For items requiring ASME Code conformance, vendors must be able to meet ASME Code requirements. Where material manufacturers or suppliers are qualified by CECO by survey, as provided under ASME Section III, and materials or items are procured directly from such qualified manufacturers or suppliers by another Certificate Holder on the basis of such survey, the qualification documentation shall be provided to the other Certificate Holder prior to its use of the materials or items. Projects Engineering and the Nuclear Engineering Department

55 Quality Assurance Coordinator will be responsible for assuring that vendor or contractor Quality Assurance Program evaluations are carried out.

The Quality Assurance / Nuclear Safety Policy and Oversight

55 Department, for the Purchasing Department, prepares and maintains the computerized Quality Approved Bidders' List (QABL) for contractors and suppliers of ASME, safety and regulatory related items.

The Purchasing Department maintains the commercial Approved Bidders List. Addition of vendors to the Quality Approved Bidders List shall only be made upon approval by the Nuclear Engineering Manager and the Manager of Quality

55 Assurance / Nuclear Safety, or their designees, as to meeting technical and quality assurance requirements.

For vendors or contractors to be placed on the Company Quality Approved Bidders List on the basis of having an approved Quality Assurance Program for ASME, safety or regulatory related items or work, a controlled copy of their approved Quality Assurance Program shall be assigned to the CECO Manager of Quality Assurance / Nuclear Safety.

SS Section 9.0 of this report, " Control of Special Processes,"

establishes the evaluation and assessment of certain process and inspection capabilities of the vendor such as welding, heat treatment, and nondestructive examination. 7.2 Evaluation of Vendors Past performance of a contractor / vendor will be considered during procurement activities by CECO. Prior to contract or purchase order award, the bidder's capability and quality performance will be reviewed relative to the product, process, or service being procured. For suppliers of ASME services or items and for Material Suppliers or Manufacturers who do not have a Quality System Certificate (Materials) or an ASME Certificate of Authorization with an appropriate scope a survey of the bidder's facilities prior to award may be required. Such review will verify ASME Code compliance as applicable. 7-2 Rev. 55 3/27/89 Commonwealth Edison

l l 7.3 Surveillance of Vendor Ooerations l Source surveillance will be carried out through' noti-fication points established as a condition of procurement of safety-related or ASME Section III items. Special consideration will be given for surveillance during manufacture when one of the following is involved: a. Determination of conformance of the item to purchase order requirements at any other poiMt would require uneconomic disassembly or destructive testing. b. Special instruments, gauges, or facilities required for inspection or test are more readily available at source end would be uneconomic to reproduce at the job site. c. A receiving inspection would destroy or require replacement of special preservation and packing. d. Quality Controls and inspections are integrated into production methods, and inspection at the suppliers plant is necessary to economically verify test reports, inspection records, certifications or other evidence of quality. Source surveillance by Commonwealth Edison Company or its agents will not nullify the vendor's responsibilities for maintaining a quality control organization delivering items conforming to procure-ment requirements. Unless otherwise specified, acceptance by Common-wealth Edison Company will be at the nuclear generating station site in accordance with the terms of the contract. The administration, surveillance and inspection of off, site equipment and material vendors will be the responsibility of the Engineering and +55 Construction Department, as applicable with final approval of inspection acceptance reports being vested in the Quality Assurance Department. 7.4 Receivino Insoection Materials and articles received from vendors will be inspected upon receipt to assure physical integrity and identity plus documentation compliance with the procurement requirements. For items not source inspected, specific receipt inspection measures such as material and dimensional checks against approved drawings and spect-fications and assurance that ASME Code Data Reports are received will be performed by qualified personnel in accordance with the applicable CECO or contractor QA program and to checklists approved by appro-priate Quality Assurance or Quality Control personnel to verify conformance to procurement requiremer+s. Where receiving inspection requires the use of calibrated instruments and tools, the identity of such equipment shall be recorded on the applicable receiving inspec-tion documents. CECO purchases Code items and turns them over to site Code contractors. In the case where receipt inspection is 7-3 Rev.55 3/27/89 Commonwealth Edison

assigned to a site contractor, CECO provides them alth applicable procurement documents, such as the Purchase Order, Specification, etc., required to assure that the CECO purchased items meet Code requirements and to perform receipt inspection. Also, for material supplied by non-Certificate holders, the CECO survey data covering such firms is made available to site Code contractors. When CECO performs receipt inspection of such purchases or when CECO upgrades stock material for ASME Code use, CECO provides these contractors with the applicable Certified Material Test Reports and/or Data l Reports plus the Material Receiving Report to provide verification that the purchased items supplied by CECO meet dode requirements. Documented evidence that material of equipment conforms to procurement requirements including, for Code items, indication of their compliance to the specified quality program must be retained and available at the site prior to use or installation. Part of this evidence shall be in the form of acceptable documentation such as Certified Material Test Reports, Pressure Test Reports, Certificates of Conformance, etc. Documentation requirements will be delineated in the individual. equipment specifications. The Construction Materials Receiving Coordinator or designee will be responsible for assuring that receiving inspection is completed where the Engineering and Construction Department is responsible for

55 the work; receipt acceptance approval will be by Quality Assurance or its designated agent.

Where ASME Section III components and safety-related materials and equipment are received by the station Stores Supervisor, station Quality Control will be responsible for receiving inspection and the Quality Assurance Engineer or Inspector for Maintenance shall assure through audit and surveillance that the receiving inspection is complete and traceability is maintained. ASHE Code material transferred from Stores or another Commonwealth

55 Edison Company station shall meet the requirements specified for the designated installation.

Nonconforming equipment will be controlled. 7.5 Sucolier Audit Vendors of safety-related and/or ASME Section III items will be subjected to survey, audit or surveillance of their quality assurance system by CECO, or its agents, at intervals consistent with the importance to safety, complexity, and the quantity of the product or services being furnished in accordance with approved agenda and checklists to assure that the necessary manufacturing processes are being utilized and that quality controls are being maintained. 116 Soare Parts and Reoacements Spare parts and replacement items, equipment and components will be purchased to original or better design requirements in accordance witn the controls herein. The applicable quality assurance requirements will be included in the procurement documents. 7-4 Rev. 55 3/27/89 Commonwealth Edison

Such spare parts and replacements from vendors will require documentation by item, component, equipment or part number for iden-tification and traceability. Documentation for material will be in accordance with procurement order requirements. Nhen the prc urement order for ASME Section III components and safety-related spare parts, material, and equipment includes a specification or drawings, docu-mentation will be received from the vendor which verifies conformance with those requirements. In the case where the original part, item, component or equipment was procured with no specifically identified quality assur-ance program requirements, or was procured from a vendor who no longer can be retained on the nuclear Quality Approved Bidders List because of an inadequate Quality Assurance Program document, identical spare parts and replacement items, components or equipment may be similarly procured from the original equipment manufacturer (OEM), but care shall be exercised to assure at least equivalent performance: that is, a joint technical engineering and quality assurance documented evaluation shall be conducted to established requirements and controls by Technical Staff or Nuclear Engineering

55 and by Quality Assurance personnel.

The evaluation shall assure that interfaces, intera angeability, safety, fit and function are not adversely affected or are contrary to applicable regulatory or code requirements. In the use of procurement of safety-related materials, parts and items that are a manufacturer's standard product (commercial grade item), such commercial grade items shall be inspected as part of the receipt inspection function to assure that: (1) damage was not sustained during shipment; (2) the item received was the item ordered (i.e., its possesses the required attributes identical, as necessary, to the item specified).; and (3) documentation, as applicable to the item, was received and is acceptable plus, after being received, such a commercial grade item shall be tested, where applicable to assure that it will perform its intended function (i.e., by means of bench testing and/or functional testing as required). A commercial grade item is one that is not subject to design, specification, or testing requirements by the supplier that are unique to nuclear power plants; is one that is used in numerous applications other than nuclear power plants; and it is one that can be ordered from the manufacturer / supplier on the basis of specifications set forth in the manufacturer's published product description (i.e., catalog) or on the basis of its manufacture to national standards. When an item is purchased by specifying the manufacturer's catalog part number, when documentation is required beyond that indicated in the catalog, and when such documentation is not available for items with the same part numtier oDtained from the manufacturer, the item does not meet the definition of a commercial grade item and shall not be treated as a commercial grade item. 7-5 Rev. 55 3/27/89 Commonwealth Edison 1

The station Stores Supervisor and station Quality Control Supervisor are responsible for assuring that documentation for spare parts and equipment has been included as part of the shipment. The documentation for the purchased material, equipment, and/or services, after being reviewed and accepted by the Quality Control Supervisor will be retained at the station. When required documentation is lacking for safety-related and/or ASME Section III components or spare parts, the Technical Staff Supervisor will verify that appropriate documentation is obtained or that suitable inspection and testing is performed to I verify conformance to procurement requirements and that such items are treated as nonconformances. Receipt inspection of spare parts and equipment purchased to ASME Section III and safety-related requirements shall be accepted by the Station Quality Assurance Engineer or Inspector.

ss 7-6 Rev. 55 3/27/89 Commonwealth Edison j

l

8. IDENTIFICATION AND CCNTROL OF MATERIALS, PARTS AND COMPONENTS A system of controls will be utilized to prevent the use of nonconforming items or items which have not received the required inspections and tests. Materials (inclu' ding consumables),

parts, and components including partially fabricated subassemblies will have their identity marked on the item or on tags and records traceable to the item. Identification assigned to materials, parts and components, including partially fabricated subassemblies, w111 be documented and maintained by the respective vendors, contractors or organizations having responsibility for the items involved throughout fabrication, installation or erection and use of the item and be verified as to being correct prior to release for fabrication, assembling, shipping or installation. The identification system for the station will be established by the Nuclear Engineering Department with assistance from the Architect

ss Engineer and Nuclear Steam Supply System vendor as needed, and consists of unique numbers assigned to pipes, instruments, valves and equipment. Also, stored spare parts, and equipment wil', be assigned established Stores Items Numbers by the Support Services
55 staff of the Stores and Inventory Control Department. Quality Assurance will assure such identification and traceability is provided.

Assigned identification of materials, parts and components will be unique to the item. Identification w111 be on j the item where practicable, and/or on records traceable to the item. Prior to dividing material or cutting the markings, the l marks or coded marking shall be transferred to the parts to be cut and such identification shall be independently verified. i l l During fabrication, installation, erection and use of items, identification will be maintained traceable to the documentation of sub-components and/or materials when specified. Engineering review will establish that stamps, tags, or labels affixing identification to an item will not affect the properties or otherwise.cause deterioration of the item and that stamps, tags and labels shall be made of material that will assure identification is not lost. The identification systems used by Commonwealth Edison Company, its contractors and major vendors for a nuclear generating station will be integrated to the extent necessary for uniformity. The identity of items, components, equipment and systems generally will be applied during the design phase. The 4 procurement of items and components will use this identity and it will be maintained during fabrication 8-1 Rev. 55 3/27/89 Commonwealth Edison

performed by vendors. The receiving inspection, erection, repair and ) maintenance records of engineered items and components which are filed at .the construction site or station will be traceable to the engineering l identity. Items and components which have not been subjected to required inspection and tests prior to receipt will be tagged or marked and controlled to preclude usage. Also, nonconforming items will be identified and controlled to preclude usage. Stored replacement spare parts and equipmen't will be similarly identified by Stores Item Numbers during purchase, storage, and I installation to assure required traceability to records and documents and to prevent their incorrect use. Part numbers are assigned by the Support

55 Services staff.

The station Stores Supervisor maintains parts, material, and equipment in storage traceable to quality assurance documents. l i 8-2 Rev. 55 3/27/89 l l Commonwealth Edison

l l

9. CONTROL OF SPECIAL PROCESSES l

l l For some processes, the required level Of quality defined in ASME Code and other applicable codes, standards and specifications cannot be assured by inspection of the item alone. For these processes, quality assurance is obtained through reliance on personnel qualification and procedural control in force as appropriate for the processes being employed for a specific task in connection with plant contract work, maintenance, repairs and modifications. The application of these controls is assured through audtt/ surveillance activities by CECO or its agent at vendor plants and/or at the. site and by Edison Quality Assurance at the operating stations. The Edison Site Quality Assurance Superintendent or designee and the Station ess Quality Assurance Superintendent at the operating station is l responsible for assuring that records of quallfled personnel are maintained by the contractor for work performed for Edison. These special and construction processes include welding, heat treating, concrete placement coating, plating, material cleaning and bonding, chemical processes, certain nondestructive testing processes and such additional processes that may be identified in the contract, purchase order or maintenance or modification procedure, as the result of ASME Section III, Division 1 and Division 2 for concrete containment requirements and/or design review. Procedures for the control of special processes will be maintained for components within the primary system pressure boundary and other safety-related items and ASME Section III designated components. These procedures will be in accordance with ASME and other applicable codes and specifications. When there is a specific reason to question whether the special process procedure or qualifications of personnel requirements are being met, the Authorized Nuclear Inspector may require requalification. Process control procedures will be used as required by specifications, Code or standards, as applicable. Supplemental procedures will be prepared as necessary to provide detailed performance and methods for control of special processes and concrete placements for concrete containments. Process control procedures will specify the preparatory steps, processing details, 9-1 l Rev. 55 3/27/89 Commonwealth Edison

conditions to be maintained during the steps of process, inspection and test requirements and records requirements. Process control procedures of contractors and vendors will be submitted to Commonwealth Edison Company for review and evaluation in accordance with documented Commonwealth Edison Company procedures. Process control procedures will specify the methods of verifying the adequacy of processing materials, solutions, and equipment, including definitions of their associated control parameters. When the process is conducted in special environments, such as in vacuum or inert gases, the process control procedures will specify the requirements and methods for maintaining such environments. j The control and approval of sub-vendor Quality Assurance and Quality Control procedures are the responsibility of the specific vendor involved (included NSSS vendor). Control procedures for nondestructive examination processes such as radiography, ultrasonic testing, liquid penetrant inspection, and magnetic particle inspection, will be used by Commonwealth Edison Company and their contractors and vendors to assure that the results provide accurate, uniform and reproducible indications of actual quality. Commonwealth Edison Company and contractor and vendor personnel responsible for the performance and verification of special processes and the inspection of concrete placement involving concrete containments and other inspection and test activities will be certified as required by specifications, ASME Code or other applicable codes and standards. Certification of personnel for such processes and concrete inspection and other inspection and test activities will include necessary training to11 owed by an examination of each individual. The period of validity for certifications shall be specified, and each individual shall be decertified at the end of such a period by retesting or by demonstration of satisfactory performance. Personnel failing retest shall be removed from operations pending requalification. Personnel who have not performed inspection, examination and test activities in the qualified area for a period of one year shall be re-evaluated to re-establish required capability. Training, testing, and qualification of personnel shall be in accordance with criteria described in ASME Code, standards and specifications. Proce'ssl ontrol records will provide objective evidence that special processes were performed in compliance with approved process control procedures by quallfled personnel. Process records will specify the inspection and test data to be verified. Results of nondestructive examinations will be recorded in accordance with applicable specifications, codes and standards. These records will be retained by Commonwealth Edison Company or when the work is contracted, they will be retained by the vendor and then supplied to Commonwealth Edison Company as required by procurement documents. 9-2 Rev. 55

ss 3/27/89 Commonwealth Edison

1 l \\ l During construction and plant maintenance and modifications assigned

55 to the Construction Department at operating stations, the responsibility for implementation of special and construction process procedures and qualification of such procedures and of personnel performing the work is that of the Engineering and Construction Department construction groups
ss and shall be under the surveillance and audit co'ritrol of the Site Quality Assurance Superintendent at the construction site and Station Quality Assurance Superintendent at 09 operating station.

During station operation, the Assistant Superintendent of

ss Maintenance assembles and maintains the qualified procedures used by station maintenance personnel or contractor under his administration. For ASME Code work and in-service inspections, nondestructive examination procedures shall be approved by a Commonwealth Edison Company NDE
55 Level III person and reviewed and signed off by the Manager of Quality Assurance / Nuclear Safety.

Heat treating and welding procedures shall be reviewed and approved by the Nuclear Engineering Manager and the Manager of Quality Assurance / Nuclear Safety. Persons performing such special processes shall be qualified in accordance with the requirements of the Code and standards. Implementation of procedures during operations is by

55 the Assistant Superintendent of Maintenance or designee and, for the most part, cover those procedures included in the Special Process Procedures Manual. Completion of inspection, tests, audits and documentation is verified by the station Quality Control group and assured by the Station
55 Quality Assurance Engineer or Inspector.

l l 9-3 Rev. 55 3/27/89 Commonwealth Edison

l

10. INSPECTION Inspection Programs will be established to provide assurance that the quality control surveillance, inspections and tests defined in the applicable equipment and concrete containment specifications are performed.

Quality Assurance inspection and testing will be conducted at vendor facilities, at the site during construction, and at the station during operatioJ), maintenance and modification activities to verify conformance to applicable drawings, instructions, and procedures as necessary to verify quality. In addition, in-service inspection will be carried out in conformance with requirements of ASME Section XI. Inspection and test control points, to be witnessed by the Authorized Nuclear Inspector, and Commonwealth Edison Company or its representative, will be established as required to assure quality of items and effectiveness of the inspection programs. Individuals performing inspections shall have the necessary qualifications and shall be independent of the individual directly responsible for performing the specific activity. Quality Assurance personnel will periodically review the inspection activities to establish their capability and to assure that required qualifications are met and kept current. Inspection personnel shall be qualifted in accordance with the requirements of the ASME Code or ANSI /ASME NQA-1, for Code and safety-related inspection activities. Equipment and material contracts with off-site vendors are administered by the Engineering and Construction Department.

55 Under the inspection programs administered and conducted by the Engineering and Construction Department of off-site vendors for
55 purchased materials, an inspection and test plan will be prepared for purchased Code and safety-related procurement based on specified engineering requirements and the specific fabrication techniques and sequences to be used for such procurement.

Approval of such a plan and approval as to the quality requirements being satisfied is the responsibility of the Site Quality Assurance Superintendent and the Station Quality Assurance Superintendent, or designees, as applicable. Inspections may take the form of source inspection, receiving inspection or both, depending on the nature, importance and quantity of the item (s) procured. Inspections will be performed to written procedures or checklists for_ inspections approved by Quality Assurance. Procurement documents shall contain provisions for Edison's right-of-access to vendors' and subvendors' facilities and records for source inspection and audit. The NSSS Supplier will conduct inspections on items procured under the NSSS contract. This does not preclude Edison inspections of those same items. 10-1 Rev. 55 3/27/89 I I Commonwealth Edison /

l l 1 The Edison Site and Station Quality Assurance Superintendent or designee, as applicable, will assure that survelliance of contractors' activities is performed in accordance with Quality Assurance approved surveillance procedures, and inspection and audit program and checklists. Edison establishes inspection notification points, including certain points designated by Quality Assurance which cannot be waived by Engineering and Construction without approval of, Quality Assurance, which

55 will be witnessed by Edison, or its designated agent. The applicable Edison Site Quality Assurance Superintendent or Station Quality Assurance Superintendent, or designees will assure that required inspection of purchased items as required and determined by Engineering is carried out, that inspection procedures, instructions or checklists specify the necessary measuring and test equipment including accuracy requirements, that contractor test procedures approved by Edison or the Architect Engineer are judiciously implemented and that procurement requirements 1

are being fulfilled. In preparing an inspection notification point witnessing plan, Edison will take into account applicable codes, standards, specifications and contractor quality control procedures. The plan for each inspection will also identify, for example, the parameters to be checked, accept / reject criteria, equipment needed for the l inspection or contractor documentation to be reviewed. Inspections associated with normal operation of the plant such as routine maintenance, surveillance and tests on safety-related mechanical and electrical equipment and systems is followed by functional or operational tests conducted in accordance with approved procedures by operations personnel. Acceptance criterion must be met before the equipment is declared operational. l Inspection and test plans shall be prepared by respective contractors, vendors or organizations having responsibility for the item (s) involved, either as a separate document identified with the parts, components or assemblies; or as an integral part of work instruction and procedure documents. Inspection and test plans shall consist of a flow chart, diagram or narrative description of the sequence of procurement, fabrication, processing, assembly, inspection and test activities and shall specify the inspection points. The criteria for selection of testing methods will be based on those needed to verify design requirements. Sampling inspection methods may be used when testLate destructive or when the quality records and the inherent inspection characteristics of the item indicate that a reduction in inspection or testing can be achieved without jeopardizing the assurance of quality. Sampling methods for Code items require prior approval of CECO or its representative as required by contract and approval shall be based on the use of a nationally recognized sampling method. 10-2 Rev. 55 3/27/89 Commonwealth Edison L_-.______________

l l Tho importanco, relativo complexity, point of acceptance, and quantity of items will determine whether manufactured items will be inspected at source or upon receipt. Source inspection is to be utilized under the same criteria as source surveillance with the additional requirement that there are control points in the contractor / supplier's manufacturing plan which must be identified for notification to CECO or its agents prior to proceeding with manufacture. Items which have been inspected at source will also require sufficient receiving inspection to assure physical integrity and identity plus documentation compliance with the procurement requirements. certification of chemical and physical properties and laboratory verification of materials will be required when indicated by applicable codes and standards, by design requirements, or as stated in the procurement documents. In-process and final inspections and tests will be used to assure conformance to design requirements for fabrication and construction work. Written procedures or checklists will be used to specify and verify final inspections and tests. Changes to approved procedures will be documented and will be reviewed and approved by personnel with equivalent engineering and quality assurance technical competence as the personnel that established the procedure. Final Test procedures and associated changes involved in ASME Section III, Division 1 and Division 2, Class CC, when CECO has overall responsibility, will be submitted to the Authorized Nuclear Inspector for review and concurrence. Inspection and test records will provide objective evidence that inspections and tests were performed in compliance with instructions and procedures to verify design and Code requirements. Inspection and test results will be recorded to show-conformance with acceptance criteria and/or record and identify the cause of rejected items. Also, inspection l and test records will identify the inspector or recorder. Data and results will be distributed to personnel who require the information for review and/or retention. Nonconforming items will be identified, segregated, and disposed of and appropriate corrective action (s) will be initiated. Rework, repair, or replacement performed after completion of inspection or tests will require reinspection and retest to the extent

33 necessary to establish acceptability to the original criteria.

10-3 l l l Rev. 33 3/13/85 CommonweaHh Edison

l l j 11. TESTCONTR0b. Test programs will be established to assure that design and performance criteria have been satisfied. The test programs will include, as appropriate, procedures to evaluate structures, systems, subsystems and components. The program will include, as applicable, proof tests prior to installation, construction, reoperation, and start-up tests as required for a new plant and operational tests, as well as those tests applicable involving and following plant 5 maintenance or modifications. Appropriate testing is performed and documented by trained or appropriately qualified personnel to assure that applicable ASME Code and safety-related structures, j systems and components perfom satisfactorily in service. .The test program will consist essentially of four testing stages: Vendor Testinzo Consists of source testing 15 such as hydrostatic testing, seismic testing, perfomance testing and environmental testing as appropriate and as reflected in the specific procurement documents for a'given ites'or items. Approved written procedures will be required for these tests and the test results will be evaluated. For items procured under the NSSS contract, the. NSSS vendor will act as Edison's agent in this regard subject to inspection and audit by Edison or its designated agent. For ncn-NSSS items, the Architect Engineer may participate with Edison Engineering or act as Edison's agent in gpproving test procedures and data. Construction Testinz: Consists of on-site component testing such as hydrostatic testing, pressure proof testing, pump and valve testing, actuation to verify proper installation and electrical continuity verification. Written procedures or checklists will be employed and the status i 11-1 Rev. 15 1/2/81 Commonwealth Edison J

of equipment both before and after testing will be documented. The various on-site service contractors will generally perform these tests. Control and management of the tests is the responsibility of the Construction Department Field Engineer.

ss The Site and Station Quality Assurance Superintendent or designee, as applicable, will be responsible for determining and assuring that proper calibrated inspection equipment is utilized, that equipment is properly released for testing, inspections and tests are done under suitable environmental conditions, that data documentation is in compliance with procedures and that retention control of test data documentation is adequate. The Authorized Nuclear Inspector shall be notified of all ASME Code hydrostatic or pneumatic tests prior to conducting them to to permit his witnessing of such tests.

Preonerational Testina: Consists of system performance tests performed prior to (or in some cases, after) core loading and are performed on completed or essentially completed systems. Preoperational tests which are performed on critical Safety Category I equipment, are controlled by approved written procedures and are evaluated in accordance with the Edison Quality Assurance Program. The Site Quality Assurance Superintendent or designee will perform a final review of all equipment releases to assure that all comments and exceptions have been resolved and will sign the release for equipment turnover to operations. Also, Quality Assurance shall monitor such tests to assure they are performed properly and evaluated by the correct people. Preoperational Testing is performed by the contractor or Edison station operating personnel. Start-Up Testina: Consists of those single and multi-system tests beginning with fuel loading which are intended to demonstrate overall plant performance. These tests include the low-power physics tests and the power escalation testing program. Those tests essential to demonstration of safe operation will be conducted under a program having the same requirements as the formal preoperational tests. Non-safety-related testing, if performed, will be controlled in a manner similar to component demonstration tests. Start-up tests will be performed by station operating personnel. 1 11-2 Rev. 55 3/27/89 Commonwealth Edison lw __

.P l l The start-up testing program commences at fuel loading and proceeds.through several power. level plateaus through 1007. 4 ) power. As applicable, the Projects Engineering Manager or

55 the Nuclear Engineering Manager of their designee (s) l approves the start-up test procedures and data.

2 l Start-up testing of systems is assigned to Technical Staff Engineers They assure that the constr'dction and preoperational tests are complete and that the start-up test procedures incorporate the requirements and acceptance criteria contained in the applicable design documents. The 1 start-up procedures review assures the prerequisites have been met, adequate test instrumentation is available for use and the tests will be performed under suitable conditions. After start-up test results are evaluated and accepted by the Projects Engineering Manager or the Nuclear Engineering

55 Manager, or their designee (s), as applicable, an acceptance statement is issued by responsible Manager or designee. The i

Site Quality Assurance Superintendent or designee assures that start-up test requirements are fulfilled. The Station Manager or Startup Superintendent, or their designees, as

55 applicable, indicates concurrence and satisfactory completion of start-up tests.

Modification testing requirements are specified by the cognizant Commonwealth Edison Company engineering department and/or Technical Staff personnel and reviewed and accepted by station Quality Control. Results from the tests are reviewed and approved by the Technical Staff Supervisor and by the Assistant Superintendent of Operating, or designee. Test

55 results which do not agree with requirements shall be forwarded to the cognizant engineering department for acceptance.

Required testing before equipment is returned to service is defined in the instrument and equipment maintenance work procedures. The acceptance of functional tests is assigned by the Assistant Superintendent of Operating to the station

S5 operation or Technical Staff personnel. The Assists.nt Superintendent of Maintenance or Quality Control Supervisor review and accept the maintenance records for completeness. The Station Quality Assurance Superintendent assures that all testing and documentation requirements are fulfilled.

11-3 Rev. 55 3/27/89 Commonwealth Edison j

Tests during operations other than routine surveillance tests are performed and documented as prescribed by the Technical Staff and Assistant Superintendent of Operating to verify continued ess satisfactory performance of safety-related structures, systems and components. The test results are evaluated by the Technical Staff and station quality control personnel. Written test procedures will be developed to demonstrate design and performance characteristics as specified in design and operating requirements. The procedures will include provisions for hold points to be established and for assuring that prerequisites have been completed and state the data to be obtained and requirements and acceptance limits to be fulfilled. Specifically, the Authorized Nuclear Inspector shall have the opportunity to establish his hold points prior to the approval of the test procedures written for the tests required by the ASME Boiler and Pressure Vessel Code Section III or XI. The tests will be performed under the appropriate conditions using adequate, appropriate, approved and calibrated test equipment. Data will be examined frequently as each test proceeds, and out-of-tolerance conditions will be recorded and described in adequate detail to permit post-test analysis. Test results will be evaluated following each test to assure conformance with design and performance requirements. The evaluation will determine the following: 1. That the appropriate test procedure was used. 2. That the data displays the adequacy of the equipment to meet the specified requirements. 3. That nonconforming or incident conditions, if applicable, are reported and corrected. Test records will include data sheets completed during the tests and a list of those instruments used for calibrating equipment. The data sheets will have provisions for identifying the person responsible for conducting the test and the date or period when the test was performed. TheorIginaltestrecordsshallbereviewedfor ~ ~ ~ completeness, identified, and indexed to establish them as a part of a permanent record to be retained. 11-4 Rev. 55 3/27/89 Commonwealth Edison

l 4 12.0 CONTROL OF MEASURING AND TEST EQUIPMENT 12.1 GENERAL Measuring and test equipment which is used to determine the acceptability of materials, parts, components, fabricated items, and completed construction assemblies.,and to perform the pre-operational testing and to ascertain the proper indications in the operation of generating station equipment will be periodically calibrated or adjusted and properly handled and stored to assure that accuracy is maintained within necessary limits in order to verify design' requirements. Such measuring and test equipment will be calibrated against standards in accordance with approved procedures having tolerance not greater than one-fourth the tolerance of the measuring and test equipment being calibrated. In situations where it is impractical to comply with the above, a standard of greater than one-fourth the tolerance but equal to or closer than the tolerance of the measurement and test equipment described will be used with proper documentation and approval. Inspection, measuring and test equipment will be adjusted and calibrated using documented procedures at scheduled intervals against certified standards having known valid relationships to recognized standards. Such procedures will provide criteria for determining the accuracy requirements of test equipment and criteria for determining when a test is required or how and when testing activities are performed. Calibration intervals for itpms will'be based upon the type of equipment, accuracy, use and other conditions affecting measurement control. Commonwealth Edison or its contractors and vendors, may provide calibrations of measuring and test equipment, or use the services of an approved calibration laboratory. In either case, 'j approved standard procedures will be used for calibration work. Standards will be maintained and used in an environment with temperature, humidity and cleanliness controls compatible with maintaining accuracy and operating characteristics of the standards. History records for measuring and test equipment will be used to indicate calibration status, condition,. correction to be applied and repair events. As a minimum, these records shall include, the equipment and Standard serial numbers, date of last l calibration, due date of next calibration, calibration data and

42 i

results as-found condition, repairs performed and, out of tolerance notification as required. 12-1 Rev. 42 11/21/86 Commonweal % dison

Traceability records will be maintained in the System Operational Analysis Department for nonradioactive certified standards to show that calibrations are traceable to recognized national standards. Also, records will be maintained in the System Operational Analysis Department for company standards as well as calibration records for inspection, measuring and test equipment. If no national standards exist, the basis for calibration will be documented. Further, the construction site or station shall maintain necessary calibration records and status and identification tagging. Reputable commercial calibration labor'a' tories shall be employed when needed and their standards will be traceable to recognized national standards. 12.2 EOUIPMENT CONTROL The basic control measure employed for measuring and test

55 equipment consists of periodic calibration using appropriate standards and documented procedures.

The control includes documentation and recording of calibrations, tagging or equivalent 1 methods to show calibration status, and, when necessary, written procedures for the use of equipment. For each piece of test and measurement equipment, the date of last calibration, the calibration data, and the due date of next calibration shall accompany the piece of equipment at the time of calibration and shall remain with the equipment until the next calibration. These items shall be identified by use of tags or stickers. Inspection and testing equipment utilized for acceptance measurements shall be identified by serial number as part of the documented inspection and testing. data. When measuring and test equipment is found to be out of calibration, an evaluation shall be made and documented of the validity of previous inspection or test results and of the acceptability of items previously inspected or tested. The Station Maintenance Department (or the Engineering and Construction

55 Department) will be notified by an out of calibration report to the user for corrective action, and to QA for correction action verification.

Written procedures appropriate to the item (s) of measuring and test equipment involved wi~11 be used to specify preoperations checks, environmental requirements, step-wise instruction, for use, and instructions for shut-down and layaway. Suppliers and contractors to Commonwealth Edison Company are required to have and employ similiar appropriate control measures l which Commonwealth Edison Company will assure through surveillance, l audit and approval of contractor procedures. The System Operational Analysis Department will be

55 responsible for calibration and maintenance of Commonwealth Edison Company measuring and test equipment. Assistance in this activity j

will be obtained from vendors or laboratories who have the necessary ( capabilities. l 12-2 ) Rev. 55 i 3/27/89 l l Commonwealth Edison j l

l The Master Instrument Mechanic is responsible for the calibration and control of station instrumentation and for the accuracy of tools, gauges, instruments and other devices used in measuring and testing such instrumentation as well as documentation of such calibration and control. The Assistant Superintendent of

55 Maintenance similarly is responsible for the calibration and control of tools, gauges and instruments used in maintenance activities. To maintain accuracy within necessary limits, the measuring and test equipment used in activities affecting quality is periodically calibrated and adjusted in accordance with Quality Procedures for test equipment and system instrumentation.

All pressure test gauges used in ASME pressure testing shall be calibrated against a standard dead weight tester or a calibrated master gauge prior to each test or series of tests. Charpy V Notch testing' machines shall be calibrated at least once each year in accordance with ASTH-E-23-72 and employing standard specimens obtained from the U.S. Army Materials and Mechanics Research Center. The associated temperature instruments shall be calibrated at least once in three month intervals or, when utilized with longer periods between use, such calibrations may be performed prior to being used. The Master Instrument Mechanic and Assistant Superintendent of Maintenance develop a master list of equipment to be calibrated. For each piece of equipment on the list, the Master Instrument Mechanic, Assistant Superintendent of Maintenance or System

ss Operational Analysis or System Materials Analysis Departments or their contractors maintain the primary standards used in the calibration of the equipment; calibrate the equipment; maintain records traceable to the instruments, tools and gauges showing the date of the last calibration, the calibration data and the due date of the next calibration; and provide records of calibration data for the station flies.

The Master Instrument Mechanic performs the instrument j survelliance testing as required by the Technical Specifications to j assure the accuracy of station process instrumentation in accordance ( with Instruments < tion Procedures. ] Instrumentation Procedures and documentation are established per the Instrumentation Procedures of the Station Procedures Manual. I l 12-3 ] Rev. 55 3/27/89 Commonwealth Edison

13.0 HANDLING, STORAGE AND SHIPPING Written procedures and instructions for handling,

26 preservation, storage and shipping will be used to specify special protective conditions neccessary to prevent damage or deterioration of materials and equipment.

The requirements needed to provide adequate receipt of material and equipment are established by Engineering in the equipment specifications or vendor instructions. Special handling procedures and instructions will be

26 provided for items that are susceptible to handling damage.

During fabrication, processing, construction, modifications, or installation, special carts, cranes, boxes, containers, and transportation vehicles will be utilized as necessary to prevent damage due to handling. Construction, installation and test sites will be provided copies of special handling instructions as appropriate. Operators of special handling and lifting equipment shall be experienced or trained in their use. Such equipment and *26 special handling tools shall be inspected and tested in accordance

with procedures and at specified time intervals.

Procedures and instructions for preservation will be

26 provided for items subject to deterioration or damage through exposure to air, moisture, or other environments during fabrication, processing, assembly, and interim storage periods.

Items will be cleaned and preserved by such methods as required to preclude deterioration. Items subject to damage will be packaged in a manner and with such materials as required to prevent damage. When maintenance of specific internal or external environments are necessary, these will be included in special packaging instructions. For items which are required to be stored for long periods of time or require special protection, storage instructions will specify special protective environments necessary to prevent deterioration and damage. Procedures and instructions will provide for adequate #26 safety, maintenance of preservation, special protective environments such as inert gas atomsphere and humidity and temperature control, periodic inspection, and periodic accountability. 13-1 Rev. 26 12/10/83 Commonwealth Edison

i Vendor's Quality Program will include shipping procedures E which will provide for inspection and control of items leaving the supplier's plant to assure the following: a. Items have_been subjected to and have satisfactorily passed appilcable insp.ections and tests. b. Items are complete and assembled as required. c. Items have been preserved and packaged in ar,cordance with applicable procedures and contract requirements. d. Packaged items have been identified and marked in accordance with applicable procedures and specifications. e. In the absence of packing and marking requirements in the contract or subcontract, the packing and marking of items will be such as to be readily identifiable at destination. f. Items shipped from a vendor will be accompanied with necessary shipping documents including special handling and storage instructions, if required. For Code items that are to be turned over by CECO to site contractors or shipped to other users, such items will be either turned over to the contractor upon delivery or turned over or shipped from the CECO site storage, with documentation required by the contractor or other user. This activity shall be performed in accordance with approved procedures or instructions. During plant construction, Projects Construction shall have

ss prime responsibility for on-site receipt, handling and storage of material and equipment. Quality Assurance shall be responsible for surveillance and audit of these activities.

The primary documents for controlling, handling, storage and shipping of items are approved written instructions or procedures which delineate acceptable techniques and necessary qualifications and precautions. A storage plan is' established by Projects Construction at each site utilizing

ss information provided by the Projects Department Project Manager and Contractor.

After licensing, the assigned Construction Engineer, when performing plant modifications, will provide surveillance of handling, storage and receipt of material and equipment for plant i modification. Inspections and audits are conducted to verify compliance with the plan or procedures and other requirements by the Edison Quality Assurance. The Construction Department Fleid Engineer

SS provides surveillance of the fleid activities of assigned contractors i

to verify the application of proper procedures and instructions for

ss the storage and handling of the equipment. When required by the terms of the purchase order, the supplier providing the spare parts, material and equipment for the Station, also provides instructions for the special handling, storage, shipping, cleaning or preservation of such items to prevent damage or deterioration.

Items received at the stations will be inspected for evidence of damage during 13-2 Rev. 55 3/27/89 i Commonwealth Edison

transit. Storage areas and facilities are provided,to assure protection of stored items. The station Stores Supervisor controls such.special handling and storage of station and other assigned spare parts, material and equipment in accordance with supplier instructions. Also, storage of chemicals, reagents (including control of shelf-life), lubricants, and other consumable materials -is controlled. Procedures and instructions to protect nuclear fuel are provided as'part of the Station Procedures Manual for use by the fuel Handling Foreman and the Nuclear Materials Custodian. I 13-3 Rev. 55

55 3/27/89 Commonwealth Edison

14. INSPECTION, TEST AND OPERATING STATUS

.The measures used to indicate the status involve two phases. The first phase is pre-receipt controls used to insure that all requisite tests and inspections scheduled to be performed at a vendor's shop have been made. The controls applied to this phase consist of vendor progress reports, inspection notification points and quality release documents which accompany the item to the site or station. The second phase consists of on-site controls and identification of status on-site or at the station. These controls consist of documented receipt inspections and item tagging to indicate nonconforming status during construction and operation phases of the nuclear generating station. This system of control will provide for the identification of items which have satisfactorily met required inspections and tests prior to arrival at the construction site. This system will also provide for indicating the quality or operating status during construction and plant operations. Farking, tags, labels, forms, log books or other suitable means are used to identify the operating status of parts and equipment to preclude inadvertent bypassing of the inspections and tests required prior to their use. The operation status of station equipment is under control of the Shift Engineer. The inspection and testing status is under control of the cognizant Organization Head (i.e., maintenance - Assistant Superintendent of Maintenance). The

ss Equipment Outage Book is maintained by the Shift Engineer to identify the operating status of station equipment taken out-of-service. A Quality Procedure describes the use of the Equipment Outage Book to assure correct identification of equipment removed _from service.

Material Receiving and Inspection Report Forms will be used to indicate the physical condition and conformance to specification. Inspection and test status during construction will be indicated by logs and test 14-1 Rev. 55 3/27/89 Commonwealth Edison I

I records. Nonconforming material and equipment will be identified i through the use of a Quality Assurance " Hold" tag. Unacceptable I material will be identified with a Quality Assurance " Reject" tag. Such " Hold" and " Reject" tags shall only be removed at the direction of Quality Assurance personnel. Operating out-of-service status is controlled by Edison " Hold" and "Out-Of-Service" cards depending on the designated internal jurisdiction of the item. The methods of control are provided through Construction and Station Operating 1 Procedures which describe the use of forms, tags and logging methods. 14-2 Rev. 26 06/19/85 Commonwealth Edison

15. NONCONFORMING MATERIALS, PARTS OR COMPONENTS AND OPERATIONS Items or conditions involving construction, maintenance

26 and modifications which are found nonconforming to the engineering requirements or specifications, drawings and instructions for modifications or workmanship standards or which are lacking required documentation upon receipt will be controlled to prevent their inadvertent use or installation.

Nonconforming items are identified, documented and segregated for disposition. Technical evaluation will be performed by qualified personnel to determine whether a nonconforming item may be accepted "as-is" repaired to an acceptable condition, or whether the item must be rejected. Items may be reworked to conform with design and/or specification requirements without technical evaluation. When items are accepted "as-is," technical evaluation will be performed to assure that the final condition of nonconforming items will not adversely affect safety, code requirements, operability or maintainability of the items, or of the component or system in which it is installed. Where ASME Code requirements are involved, disposition acceptance by the Authorized Nuclear Inspector shall be required. Nonconforming items accepted "as-is," or reworked to an acceptable condition shall be identified through documentation records and in a manner that will establish the condition as installed. Where an item is in non-conformance with ASME Code

26 requirements it shall not be dispositioned as "use-as-is".

When the responsible CECO personnel authorizes acceptance of the item "as-is," or rework of the nonconforming item, the action will be documented. Such action involving vendor product prior to shipment to the site will be identified in shipping documents or certificates of conformance and reviewed and approved by the Site Quality Assurance Superintendent or the Station Quality Assurance Supervisor or their designees to assure that nonconformance has been resolved and corrective action completed. 1 15-1 Rev. 26 12/10/83 Commonwealth Edison

Rejected items shall be identified by tagging and ) immediately removed from construction or installation areas (unless physical size prohibits this) and segregated in a controlled area to prevent its uncontrolled use or installation. Commonwealth Edison Company will make a technical evaluation of pertinent data relating to the nonconformity, including the cause, where known, and corrective action either taken or planned to prevent recurrence. Also, items which are found to contain defects which could create a substantial safety hazard will be' reported in accordance with the provisions of 10CFR Part 21 and as provided in implementing procedures. Construction deficiencies involving material or equipment are documented and reported to the Nuclear Regulatory Commission and to Commonwealth executive management. The Projects Construction

55 Superintendent or the Engineering and Construction Department Construction Superintendent, or designee, is responsible for this reporting.

The Station Manager is responsible for investigating and reporting operating occurrences. An Investigative Report is prepared for occurrences or departures from the safety limits prescribed in the Station Technical Specifications. Occurrences and departures from the safety limits are documented and reported to the NRC as required by the Technical Specifications. The Station Manager appoints personnel to investigate the occurrence and issue an Investigative Report in accordance with the Technical Specifications and a Quality Procedure. This report is distributed to the Vice Presidents (BHR and PHR Operations) and

5S Station Managers.

Reports of occurrences that result in significant damage or have significant safety implications are reviewed with the Vice President (BNR or PHR Operations), or his designee, and then

55 forwarded to other executive management.

The appointed personnel are responsible for determining the cause of the occurrence, developing recommendations intended to preclude recurrence and issuing a report which shall include: a detailed description of the occurrence, the findings and recommended measures for corrective action. When deviation from accepted normal operation of a reactor and its associated equipment occurs, or when a reactor scram occurs (other than those associated with a reportable occurrence), the Station Technical Staff investigates the deviation and issues a Deviation Report covering the nature of the deviation (e.g., process difficulty, equipment inadequacy, procedure inadequacy), its cause, ) the hazard or potential hazard to operations and recommendations for ) corrective action. 15-2 Rev. 55 3/27/89 ) Commonwealth Edison

4 .The report documents the deviation and provides a record from which to estabitsh a trend in the operation. Such reports are distributed to the Vice Presidents (BWR and PHR Operations), the Production '55 Superintendent, Technical Staff Supervisor, Nuclear Quality Programs Manager, and Manager of Quality Assurance / Nuclear Safety. The Assistant Superintendent of Maintenance and Master Instrument Mechanic receive a copy of.the deviation report if maintenance or instrumentation work is involved in the correction of the deviation. Reports involving significant reactor s'dfety considerations are reviewed with the cognizant Vice President (BHR and PHR

ss Operations) and then forwarded to other executive management.

Such deviations will be reported to the Nuclear Regulatory Commission as required by the Technical Specifications. During construction, the Projects Department Project

ss Manager and, during plant modification, the Nuclear Engineering Department Design Superintendent / Supervisor, has responsibility for resolution of nonconformances and such resolution will be approved by.the Site Quality Assurance Superintendent or designee at the construction site or by a Station Quality Assurince Superintendent
55 or designee at the operating station.

Nonconformance to system operation and technical specification requirements will be resolved through actions by the Production Superintendent with the approval of the Station Manager. 15-3 Rev. 55 3/27/89 Commonwealth Edison

l 16.0 CORRECTIVE ACTION A corrective action system will be used'to assure that such items as failures, malfunctions, deficiencies, deviations, defective material and equipment, nonconformances and programmatic deficiencies which are adverse to quality and might affect the safe operation of a nuclear generating station are promptly identified and corrected. Corrective action measures for nonconformances are included in the design, source fabrication and on-site construc-tion, erection and operational phases. Correttive action measures involving design will be processed as design change requests. Corrective action measures in the source fabrication phase are required in the quality assurance programs of individual vendors including the NSSS Supplier. For construction undertaken by Projects Engineering and

ss for modifications installed under the direction of Engineering and Construction, on-site corrective action measures shall consist of a program for:

(1) reporting nonconformances to Engineering by Construction; (2) recording nonconformance reports (NCR's) in a log for follow-up by Quality Assurance as to resolution and satisfactory completion; (3) prompt resolution and approval of corrective actions by Engineering; (4) assurance by Construction that the corrective action has been taken; (5) sign-off approval and close-out of NCR's by Site Quality Assurance that satisfactory corrective action has been taken; and (6) issuance by Engineering of monthly reports indicating the status of all NCR's submitted for resolution. Implementation of corrective action will be accomplished i at the source of deficiency by appropriate contractor personnel as found necessary by the contractors or as directed by cognizant Edison engineers. Projects Construction or Engineering and

SS Construction, as applicable, has responsibility for implementation of the correction. Quality Assurance is responsible for follow-up and final approval that the nonconformances have been corrected j

satisfactorily. For corrective action nonconformances, the Edison Site Quality Assurance Superintendent or designee will establish and maintain a Nonconformance Report (NCR) Station Log to monitor the prompt resolution and closing of all NCR's plus maintain a file of all NRC's or equivalent documents that are submitted by the site for CECO resolution and approval. 16 ; Rev. 55 3/27/89 Commonwealth Edison

The cumulative monthly deviation report, which indicates i the NCR number, deviation description and resolution, such as reject, replace, use-as-is or repair, approval status, date of resolution and whether corrective action is completed, is distributed to involved corporate and line management for information, review and possible action. The responsible manager { brings significant nonconformances to the attent, ion of corporate management for action where satisfactory resolutfon cannot be i achieved by Engineering with a contractor. For Operations, corrective action identified from nonconformances, incidents and deviations, trend studies and audits are verified for satisfactory completion to preclude repetition. When corrective action is required to correct nonconformance to Code requirements, such corrective action shall be made available to the Authorized Nuclear Inspector. Any revision to Travelers or other process control documents involved with

55 corrective action related to nonconformance for station modifications shall be reviewed with the Authorized Nuclear Inspector for his review and insertion of hold points.

The Technical Staff Supervisor verifies completion of corrective actions for maintenance, repair, refueling and operation activities. The Station Quality Assurance Superintendents, or designees, issue reports indicating the status of corrective action

ss in progress.

These reports are routed to the Vice Presidents (BNR and PHR Operations), the Nuclear Quality Programs Manager, and the Manager of Quality Assurance / Nuclear Safety and reviewed to ensure prompt implementation of the corrective action. This system will provide follow-up to assure that corrective measures are effectively implemented. Also, significant conditions are reported by the responsible manager and nonconforming items are routinely reported by the responsible engineering organization to appropriate levels of management. Site contractors and off-site vendors will be required to follow-up on corrective action commitments within their quality program. The Site Quality Assurance Superintendent or designee will be responsible for surveillance of site corrective action. The Projects Department Project Manager is responsible for assuring that

55 review and evaluation of nonconformance reports are carried out to determine the need of corrective action.

Quality Assurance is responsible to track and verify completion of corrective action taken for audit deficiencies including programmatic deficiencies identified in audits. 16-2 Rev. 55 3/27/89 I Commonwealth Edison

4 Required corrective action during Station operation which I is due to equipment malfunctions and/ or abnormal occurrences will I be incorporated into the station maintenance and operating procedures in a timely manner to preclude repetition. The responsible Quality Assurance Engineer or Inspector assigned to the station verifles and i - approves the completion of corrective actions by the station. Deficiencies in implementing corrective actions.will be brought to the attention of appropriate management levels for resolution. l i 16-3 Rev. 15 1/2/81 Commonwealth Edison

[ l

17. QUALITY ASSURANCE RECORDS Quality assurance records will be maintained either by i

Edison or by an agent of Edison, under Edison's control. The location, means of identification, duration of retention and means of retrieval will vary depending on the nature of the individual l records. Quality assurance records will be stored in a predetermined location as necessary to meet ths requirements of appilcable standards, codes and regulatory agencies. The storage location or facility shall be adequate for the maintenance, preservation and protection of the quality assurance record flies from the time of receipt until their ultimate disposal. Fabrication and construction authenticated documentation is generated by contractors and vendors.for Commonwealth Edison Company, and will be available at the construction site or as directed by procurement documents. Required documentation is identified when records are stored at locations other than the site, a record wl'1 be maintained at the site to identify these records and their location 9e.g., NSSS equipment documentation). Records generated during site construction, testing, operations and plant modifications will be available at the station as originals or reproduced copies. Upon completion of construction records will be turned over to the station for retention for the life of the plant or otherwise required retention periods provided by Regulations or the ASME Code. Records are retained and maintained in accordance with a Quality Procedure to furnish evidence of activities affecting quality. The station quality. assurance records are retained and maintained by the station personnel in accordance with written station procedures and regulatory and national Standard requirements. The methods of storage, preservation and safekeeping of the records are selected to minimize damage, deterioration 4r.-loss. Quality assurance records are to be legible, indexed, identifiable, reproducible and retrievable as well as complete and accurate as to material respects. These authenticated records include items which are related to the safe operation of the station; which document the as-built requirements of equipment and systems for use in maintaining, reworking, repairing or modifying station equipment; which can assist in determining the cause of a malfunction of an item that provides protection to the health and safety of the public; and which provide inspection data for in-service inspection. 17-1 Rev. 51 7/7/88 Commonwealth Edison

i The lifetime quality assurance records, including audit reports are those continually maintained for the operating life of particular ASME Code and safety-related item or component while it is installed in the Station or stored for future use. Records to be i kept as required for the life of the plant shall be designated. For ASME items, lifetime and nonpermanent records shall be maintained as provided by Section III of the ASME Code. The Nuclear Quality Programs Manager wil.1 be responsible

ss for assuring that records are retained by Construction during

) engineering and construction. Following start-up, the Station 1 Manager will be responsible for the retention of station operating, j maintenance and modification records for the life of the plant or for the period of time established by Commonwealth Edison Company Procedures. j Quality records will be received, evaluated, stored and

ss retrievable.

The certified design specification and a copy of acceptance verification for the design reports for safety-related and ASME Section III Division 1 items and the certified design and construction specifications, and certified design and construction reports for ASME Division 2, concrete containment, will become part of the permanent records file to be retained for the life of the item or the life of the plant, at the plant site, the manufacturing plant, the Architect Engineer or other designated locations. Files shall be maintained current, complete and available for audit by Commonwealth Edison Company or its agents, the Nuclear Regulatory Commission and the Authorized Nuclear Inspector at any reasonable time during the retention period. Contractors and suppliers shall retain their quality records as required by applicable codes, standards and contract requirements. At the end of the required retention period, the contractor or supplier shall transfer these records to the Commonwealth Edison Company Projects Construction Superintendent or Engineering and Construction

ss Construction Superintendent or designee for transfer to the Station Manager or filing for the life of the plant. In no case will the file be destroyed by the contractor or vendor without written instruction by Commonwealth Edison.

17-2 Rev. 55 3/27/89 Commor. wealth Edison L__-_____-__-____--_--____.

l 18.' AUDITS Audits will.be performed by Commonwealth Edison Company and/or'its contractors, subcontractors and vendors to verify the implementation and effectiveness of quality programs under their j cognizance. The number and experience of persons participating in audits will vary according to the nature and significance of the audit. f ' Audits under the responsibility of the Nuclear Quality

55 Programs Manager and the Superintendent of Off-Site Audits will cover quality systems for engineering, construction, modifications, maintenance, in-service inspectton and Stores activities. Audits will be performed to evaluate the implementation of the quality assurance programs, the adherence to
55 procedures and controls and the fulfillment of. requirements.

i Certifications and records will also be evaluated. Product audits assess the effectiveness of in-progress work, inspections and tests that ars specific to the fabrication, installation, construction, testing and operation of an item. The performance and compitance of each operating station to the Quality Assurance Program is assured through review surveillance and audit of operations by the Quality Assurance Engineers or Inspectors under the direction of the Station Quality Assurance Superintendent, who is responsible through review, surveillance and audit of operating, maintenance, modifications, Stores and in-service inspection activities by Quality Assurance Engineers or Inspectors to the Nuclear Quality Programs Manager

55 and the Superintendent of Off-Site Audits. Audits are performed to audit schedules which are approved by the Manager of Quality Assurance / Nuclear Safety.

These schedules include the minimum

55 audits required. Other audits will be performed as directed by Quality Assurance supervision.

The Lead. Auditor's audtting organization shall develop and document an audit plan for each audit. This plan shall identify the audit scope, requirements, audit personnel, activities to be audited, organizations to be notified, applicable documents, schedule, and written procedures or checklists. Audits will be conducted using checklists or an agenda approved by

ss trained, qualified and responsible Quality Assurance supervisory personnel and will be conducted with sufficient authority and organizational freedom to evaluate compliance with all applicable aspects of the Quality Assurance Program and specified requirements.

Audits will be initiated early to assure effective quality assurance during design, procurement, manufacturing, J l i 18-1 Rev. 55 4 3/27/89 Commonwealth Edison }

construction and'insta11ation, inspection hnd test and be performed efficiently in order to achieve 6 minimum of interference with work In progress and minimum disruption of organizations being audited. An audit plan will~be maintained in order to schedule audits of site contractors. Audits of off-site contractors generally will be conducted in conjunction with plant visits for witnessing inspection points by a qualified auditor. Also, periodically Quality Assurance will participate in such audits or perform independent audits to assure effectiveness of the program, compliance to the program and fulfillment of procurement requirements. The elements in the quality program, in' procurement docu-ments and in related codes and standards, are subject to systems audits.- Also, items received, fabricated and. constructed or installed for use by Commonwealth. Edison Company in its nuclear power plants are subject to audits. Audits will be performed selectively at various stages of contracts on a varying frequency, based on the nature and safety i significance of the work being done to verify compliance and determine the effectiveness of procedures, inspections, tests, process controls and documentation. For Code materials, when a Material Manufacturer or Material Supplier, as applicable, does not hold a Quality System Certificate (Materials), the CECO audit frequency shall be.at least once annually during the interval in which CECO purchased material is being controlled by the Material Manufacturer or Material Supplier. In addition to these audits, Quality Assurance will conduct approximately annually, overall system audits of the NSSS vendor, the Architect Engineer, site contractors, vendors of services, and involved Edison Departments. Audits of CECO are also performed by the Authorized Inspection Agency as required by the ANSI N-626 series of Standards. For operating stations, periodic Quality Assurance audits

ss will be performed to verify compliance with, and the effectiveness of, the program. Audits covering operating will be performed in accordance with the Technical Specifications under the direction and responsibility of the Nuclear Quality Programs Manager and the
ss Superintendent of Off-Site Audits, as applicable, independent of the Production Department. Surveillance, review and audits covering maintenance, modifications, in-service inspection and Stores activities performed by the station organizations will be performed under the direction and responsibility of the Nuclear Quality
ss Programs Managerand the Superintendent of Off-Site Audits, as applicable, and under the direction and responsibility of the Nuclear Quality Programs Manager and the Superintendent of Off-Site
ss Audits, as applicable, where maintenance and modifications are performed by contractors or other organizations under the direction of the Engineering and Construction Department for the sfations.
ss Audit results and recommendations of corrective action w+11 be documented and reviewed with the management of the Station.

Deficiencies requiring prompt corrective action are reported immediately to management of the audited organization. Verification 18-2 Rev. 55 3/27/89 Commonwealth Edison I

.l of the completion of corrective action recommended in audit reports l will be performed by the Technical Staff Supervisor or Quality Control Supervisor. Follow-up of open station items is tracked by the Action Item Records (AIR) System. Where an audit item is placed under the AIR system for tracking completion, approval as to satisfactory completion of corrective action shall be obtained from the responsible station Quality Assurance Engineer or Inspector. Audits will be established and conducted by quallfled personnel who are familiar with written procedur'ds, standards and processes applicable to the area being audited, but who do not have direct responsibilities in the areas being audited. .An audit report shall be written for each audit. An audit

55

) report package consisting of Summary Sheet, Attachment Sheet, Checklists or Agenda and any additional pertinent details recorded on additional sheets necessary.to support a finding (s) will be on file. The audit report will be reviewed, signed, and dated by the Lead Auditor and should be signed by the auditor (s). The audit shall be reviewed for acceptability by a supervisor. The audit report shall be sent, as applicable, to the President, Senior Vice President (Nuclear Operations), Manager of Engineering and Construction, the Nuclear Engineering Manager, Manager of Quality Assurance / Nuclear Safety and Superintendent of Off-Site Audits, Assistant Vice President (Quality Programs and Assessment) and the

3, Nuclear Quality Programs Manager, and the Vice Presidents (BWR and PHR Operations) for management review and action.

The above stated system audits are also sent to the Chairman and CEO and the President and Chief Operating Officer for review and evaluation and

55 action as deemed necessary by the Manager of Quality Assurance / Nuclear Safety. Also, monthly to bi-monthly periodic reports on quality assurance activities are submitted to top management.

Such reports, in part, provide bases for periodic top management reviews and discussions of quality assurance activities, 3 implementation status and effectiveness. Such reviews and discussions are held by the Chairman and President.with the Manager

55 of Quality Assurance / Nuclear Safety and with other executives.

Audits shall be scheduled and follow-up review of deficient areas or adverse conditions and follow-up on corrective action l commitments shall be performed by Quality Assurance to assure j effective corrective action and implementation have been carried out. Deficiencies in the execution or implementation of corrective action will be brought to the attention of the person who is responsible in the area involved. Continued deficiencies, or failure to implement corrective action will be reported in writing by Quality Assurance to appropriate executives within Commonwealth Edison Company. 18-3 1 Rev. 55 3/27/89 Commonwealth Edison i}}

ML20245F870

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